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Home My WebLink About02-4172WASHINGTON MUTUAL BANK, FA FIKIA PNC MORTGAGE CORP. OF AMERICA Plaintiff vs. ANGIE M. WATSON AND ROBERT E. WATSON, III Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA 02- g17A,, CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE THIS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTINGTO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after the Complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claim in the Complaint of for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 AVISO LE HAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUEJAS PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SER SERVIDO CON ESTA DEMANDA Y AVISO. PARA DEFENDERSE ES NECESSARIO QUE USTED, O SU ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL PUNTO DE VISTA DE USTED Y CUALQUIER OBJECCION CONTRA LAS QUEJAS EN ESTA DEMANDA. RECUERDE: SI USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL PROCESO SIN SU PARTICIPACION. ENTONCES, LA COUTE PUEDE, SIN NOTIFICARIO, DECIDIR A FAVOR DEL DEMANDANTE Y REQUERIRA QUE USTED CUMPLA CON TODAS LAS PROVISIONES DE ESTA DEMANDA. POR RAZON DE ESA DECISION, ES POSSIBLE QUE USTED PUEDA PERDER DINERO, PROPIEDAD U OTROS DERECHOS IMPORTANTES. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATEAMENTE. SI NO CONOCE A UN ABOGADO, LLAME AL "LAWYER REFERENCE SERVICE" (SERVICIO DE REFERENCIA DE ABOGADOS), (215) 238-6300. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 WASHINGTON MUTUAL BANK, FA FIK/A PNC MORTGAGE CORP. OF AMERICA, Plaintiff VS. ANGIE M. WATSON AND ROBERT E. WATSON, III, Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW ACTION OF MORTGAGE FORECLOSURE THE FOLLOWING NOTICE IS BEING PROVIDED PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. 1601 The undersigned attorney is attempting to collect a debt owed to the Plaintiff, and any information obtained will be used for that purpose. The amount of the debt is stated in this Complaint. Plaintiff is the creditor to whom the debt is owed. Unless the Debtor, within thirty (30) days after your receipt of this notice disputes the validity of the aforesaid debt or any portion thereof owing to the Plaintiff, the undersigned attorney will assume that said debt is valid. If the Debtor notifies the undersigned attorney in writing with the said thirty (30) day period that the aforesaid debt, or any portion thereof, is disputed, the undersigned attorney shall obtain written verification of the said debt from the Plaintiff and mail same to Debtor. Upon written request by Debtor to the undersigned attorney within said thirty (30) day period, the undersigned attorney will provide debtor with the name and address of the original creditor if different from the current creditor. PURCELL,KRUG & HALLER 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 Attorney I.D.# 15700 Attorney for Plaintiff WASHINGTON MUTUAL BANK, FA F/K/A PNC MORTGAGE CORP. OF AMERICA, Plaintiff VS. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW ACTION OF MORTGAGE FORECLOSURE ANGIE M. WATSON AND ROBERT E. WATSON, III, Defendants COMPLAINT IN MORTGAGE FORECLOSURE 1. Plaintiff, WASHINGTON MUTUAL BANK, FA F/K/A PNC MORTGAGE CORP. OF AMERICA, is a corporation, with an address of P.O. BOX 1169, DEPT. 2665 MILWAUKEE, WISCONSIN 53201. 2. Defendant, ANGIE M. WATSON, is an adult individual, 145 FAITH CIRCLE, PENNSYLVANIA 17013. Defendant, ROBERT E. WATSON, III, is an adult individual, whose last known address is 145 FAITH CIRCLE, CARLISLE, PENNSYLVANIA 17013. 3. On or about, March 27, 1998, the said Defendants, executed and delivered a Mortgage Note in the sum of $78,859.00 payable to PNC MORTGAGE CORP. OF AMERICA, which Note is attached hereto and marked Exhibit "A" 4. Contemporaneously with and at the time of the execution of the aforesaid Mortgage Note, in order to secure payment of the same, Defendants made, executed, and delivered to original Mortgagee, a certain real estate Mortgage which is recorded in the Recorder of Deeds Office of the within County and Commonwealth in Mortgage Book 1441, Page 622 conveying to original Mortgagee the subject premises. PNC Mortgage Corp. of America is now known as Washington Mutual Bank, FA. The Said Mortgage is incorporated herein by reference. 5. The land subject to the Mortgage is: 145 FAITH CIRCLE, CARLISLE, PENNSYLVANIA 17013 and is more particularly described in Exhibit "B" attached hereto. 6. The said Defendants are the real owners of the property. The Mortgage is in default due to the fact that Mortgagors have failed to pay the installment due on May 01, 2002 and all subsequent installments thereon, and the following amounts are due on the Mortgage: UNPAID PRINCIPAL BALANCE Interest at $16.07 per day From 04/01/2002 To 09/01/2002 ( based on contract rate of 7.750%) Accumulated Late Charges Late Charges $28.16 From 05/01/2002 to 09/01/2002 Escrow Balance Attorney's Fee at 5% of Principal Balance TOTAL $75,716.58 $2,458.71 $197.16 $112.64 $405.48 $3,785.83 $82,686.40 "Together with interest at the per diem rate noted above after September 01, 2002 and other charges and costs to date of Sheriff's Sale. The attorney's fees set forth above are in conformity with the Mortgage documents and Pennsylvania law, and will be collected in the event of a third party purchaser at Sheriff's Sale. If the Mortgage is reinstated prior to the sale, reasonable attorney's fees will be charged that are actually incurred by Plaintiff. 8. No judgment has been entered upon said Mortgage in any jurisdiction. 9. Notice of intention to foreclose and accelerate the loan balance pursuant to Pennsylvania Act No. 6 of 1974 is not required in that the original principal balance exceeds $50,000.00. 10. Defendants are not members of the Armed Forces of the United States of America, nor engaged in any way which would bring them within the Soldiers and Sailors Relief Act of 1940, as amended. 11. The within Mortgage is insured by the Federal Housing Administration under Title II of the National Housing Act and, as such, is not subject to the provisions of Pennsylvania Act No. 91 of 1983. WHEREFORE, Plaintiff demands judgment in mortgage foreclosure "IN REM" for the aforementioned total amount due together with interest at the rate of 7.750% ($16.07 per diem), together with other charges and costs including escrow advances incidental thereto to the to of Sheriff's Sale and for foreclosure and sale of the property within described. By: PUR L, G & HAL ER Leon . Haller, Esquire Attorney for Plaintiff I.D. # 15700 1719 N. Front Street Harrisburg, PA 17102 (717-234-4178) FmC88427.tit (1696x2200x2 titt) L15J Multistate LENDER'S #: 02-24-90360 NOTE PHA Ceae if, L441:5616238-203 MARCH 27, 1986 [Date] 145 FAITH CIRCLE, CARLISLE, PENNSYLVANIA 17013-8889 [Property Address] L PARTIES "Borrower" means each person signing at the end of this Note, and the person's successors and assigns. "Lender" means PNC MORTGAGE CORP. OF AMERICA, AN OHIO CORPORATION and its successors and assigns, 2. BORROWER'S PROMISE TO PAY, INTEREST In return for a loan received from Lender, Borrower promises to pay theprincipal sum of ------------------------ SEVENTY-EIGHT THOUSAND EIGHT HUNDRED FIFTY-NINE DOLLARS AND ZERO CENTS--------------------------------------- ------------------------------------------------------------------------------------------ Dollars (U.S. $ 78,859.00 ------------- ), plus interest, to the order of Lender. Interest will be charged on unpaid principal, from the date of disbursement of the loan proceeds by Lender, at the rate of SEVEN AND THREE FOURTHS -------- Pereent (------------------7.750 %) per year until the full amount of principal has been paid. 3. PROMISE TO PAY SECURED Borrower's promise to pay is secured by a mortgage, deed of trust or similar security instrument that is dated the same date as this Note and called the "Security Instrument," The Security Instrument protects the Lender from losses which might result if Borrower defaultsunder this Note. 4. MANNER OP PAYMENT (A) Time Borrowe MAY I , 1998 Any r shall make a paymentof principal and interest to Lender on the first day of each month beginning on 2028, will be dueonthatdate,whichiscalledtheand interest "MaturityDaten"mgonthefirstdayof APRIL (B) Place Paymentshallbe madeat 75 NORTH FAIRWAY DRIVE, VERNON HILLS, ILLINOIS 60061 writing by notice to Borrower, or at such place as lender may designate in (C) Amount Each monthly payment of principal and interest will be in the amount of U.S. $ 564.96--------------------- This amount will be part of a larger monthly payment required by the Security Instrument, that shall be applied to principal, interest and other items in the order described in the Security Instrument. (D) Allonge to this Note for payment adjustments If an alonge providing for payment adjustments is executed by Borrower together with this Note, the covenants of the Alonge shall be incorporated into and shall amend and supplement the covenants of this Note as if the allonge were a part of this Note. [Check applicable box) 0 Graduated Payment Allonge 0 Growing Equity Allonge 0 Other [specify] 5. BORROWER'S RIGHT TO PREPAY Borrower has the right to pay the debt evidenced by this Note, in whole or in part, without charge or penalty, on the first day of any month. Lender shall accept prepayment on other days provided that borrower pays interest on the amount prepaid for the remainder of the month to the extent required by Lender and permitted by regulations of the Secretary. If ® PHA Multistate Fixed Rate Note - IMS '?e-tll'"Oe XC30500M. 1W.03 it" VMP MORTGAGE FORMS - (800)521.7291 ..". t s. = initialc? I III?? II?1 ??I?IIuI N?I OII??? "A 1, Fmc88427.tit (1696x2200x2 titt) L16) Borrower makes a partial prepayment, there will be no changes in the due date or in the amount or the monthly payment unless Lender agrees in writing to those changes. 6. BORROWER'S FAILURE TO PAY (A) Late Charge for Overdue Payments If Lender has not received the full monthly payment required by the Security Instrument, as described in Paragraph 4(C) of this Note, by the end of fifteen calendar days after the payment is due, Lender may collect a late charge in the amount of FOUR--------------------------------------- -Pet'cent (------------------- 4.000 %) of the overdue amount of each payment. (B) Default If Borrower defaults by failing to pay in full any monthly payment, then Lender may, except as limited by regulations of the Secretary in the case of payment defaults, require immediate payment in full of the principal balance remaining due and all accrued interest. Lender may choose not to exercise this option without waiving its rights in the event of any subsequent default. In many circumstances regulations issued by the Secretary will limit Lender's rights to require immediate payment in full in the case of payment defaults. This Note does not authorize acceleration when not permitted by HUD regulations. As used in this Note, "Secretary" means the Secretary of Housing and Urban Development or his or her designee. (C) Payment of Costs and Expenses If Lender has required immediate payment in full, as described above, Lender may require Borrower to pay costs and expenses including reasonable and customary attorneys' fees for enforcing this Note to the extent not prohibited by applicable law. Such fees and costs shall bear interest from the date of disbursement at the same rate as the principal of this Note. 7. WAIVERS Borrower and any other person who has obligations under this Note waive the rights of presentment and notice of dishonor. "Presentment" means the right to require Lender to demand payment of amounts due. "Notice of dishonor" means the right to require Lender to give notice to other persons that amounts due have not been paid. 8. GIVING OF NOTICES Unless applicable law requires a different method, any notice that must be given to Borrower under this Note will be given by delivering it or by mailing it by first class mail to Borrower at the property address above or at a different address if Borrower has given Lender a notice of Borrower's different address. Any notice that must be given to Lender under this Note will be given by first class mail to Lender at the address stated in Paragraph 4(B) or at a different address if Borrower is given a notice of that different address. 9. OBLIGATIONS OF PERSONS UNDER THIS NOTE If more than one person signs this Note, each person is fully and personally obligated to keep all of the promises made in this Note, including the promise to pay the full amount owed. Any person who is a guarantor, surety or endorser of this Note is also obligated to do these things. Any person who takes over these obligations, including the obligations of a guarantor, surety or endorser of this Note, is also obligated to keep all of the promises made in this Note. Lender may enforce its rights under this Note against each person individually or against all signatories together. Any one person signing this Note may be required to pay all of the amounts owed under this Note. BY SIGNING BELOW, Borrower accepts and agrees to the terms and covenants contained in this Note. ,C'r r _ (Seal) 60BE/RT? E WATSON I11 -Borrower (iAi1?letfJ// (Seal) GIE M jV'ATSON " -Borrower (M-fflimou xansoo&iv m.e3 v9s _ (Seal) -Borrower _ (Seal) -Borrower _ (Seal) Borrower (Seal) -Borrower PAY TO THE ORDER OF: (Seal) WITHOUT RECOURSt -Borrower pNC rtgage Corp. of America e (Seal) orrower Satratary M.,. 2 of 2 00 E. VWasasi FMC88427.tif (1696x2200x2 tiff) (1.0J ALL that certain tract or parcel of land, with the buildings and improvements thereon erected, SITUATE in the Township of North Middleton, County of Cumberland, Commonwealth of Pennsylvania and described in accordance with a Plan of Property made by Lary V. Neidlinger, dated February 28, 1980, as follows, to wit: BEGINNING at an iron pin on the Westerly side of Faith Circle (60 feet wide), at a corner of Lot No. 156; thence extending from said point of beginning and along Lot No. 156; North 89 degrees 34 minutes 18 seconds West, the distance of 357.90 feet to a point, in line of lands of Kingsbrook Section 11; thence extending along the last: mentioned lands, the two (2) following courses and distances, (1) North 25 degrees 25 minutes 35 seconds West, the distance of 15.77 feet to a point, and (2) North 43 degrees 317 minutes 42 seconds East, th e distan ce of 49.02 feet to a point, at a corner of Lot No. 108; thence extending along Lot No. 108, South89 degrees 34 minutes 18 seconds East, the distance of331, 29feet to an iron pin on the Westerly side of Faith Circle; thence extending along the said side of Faith Circle, South 00 degrees 25 minutes 42 seconds East, the distance of 50.00 feet to the first mentioned point and place of BEGINNING. BEING known and numbered as 145 Faith Circle. BEING shown as Lot Nos. 109 and 156-B on the plan of Mngsbrook, as recorded in Plan Books: 27 at Page 3 and 36 at Page 19. UNDER AND SUBJECT, NEVERTHELESS, to all rights of way, easements, restrictions and/or conditions of record. BEING the same premises which Ernest A. Hoffstetter and Muriel Hoffstetter, his wife, by deed of even date and about to be recorded herewith, granted and conveyed unto Robert E. Watson, III and Angie M. Watson, the Mortgagors herein Stara Of Pennsylvania County of Cun7berland) iiscoreed i klieoffficefo., hearlarr in 8 witn my ha Carli , PA t ' 00K1,44f igr 630 88 COMPANY NAME: as mALAL Bw, FA F/K/A 1c mimiAm as p. cF x4RRA VERIFICATION I verify that the statements made in the foregoing Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Dated rLUSr 28, 2002 d C= r n /? y L., ? , 'i 'fl OV3 SHERIFF'S RETURN - REGULAR CASE NO: 2002-04172 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WASHINGTON MUTUAL BANK VS WATSON ANGIE M ET AL HAROLD WEARY Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon WATSON ANGIE M the DEFENDANT at 0015:55 HOURS, on the 18th day of September, 2002 at 7 PINEY COURT GARDNERS, PA 17324 by handing to ANGIE WATSON a true and attested copy of COMPLAINT MORT FORE NOTrrP together with and at the same time directing Her attention the contents thereof. Sheriff's Costs Docketing Service 18.00 Affidavit 4.14 Surcharge .00 10.00 .00 32.14 Sworn and Subscribed to before me this day of (J?IcT, d a A.D. rothonotary So Answers: R Thomas Kline 09/19/2002 PURCELL, KRUG & HALLER By•- 7! ti" yt I ---Piny Sneriy? SHERIFF'S RETURN - REGULAR CASE NO: 2002-04172 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WASHINGTON MUTUAL BANK VS WATSON ANGIE M ET AL STEVE WHISTLER , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon III the DEFENDANT at 0009:20 HOURS, on the 12th day of September, 2002 at CUMBERLAND CO. SHERIFFS OFFICE 1 COURTHOUSE SQUARE CARLISLE, PA 17013 by handing to ROBERT E. WATSON, III a true and attested copy of COMPLAINT - MORT FORE together with NOTICE and at the same time directing His attention to the contents thereof. Sheriff's Costs Docketing Service 6.00 Affidavit 3.45 Surcharge 00 .00 10.00 .00 19.45 Sworn and Subscribed to before methis 7 0- day of - 00 A.D. + n In DD ??- Prothonotary So Answers: e07 or R. Thomas Kline 09/19/2002 PURCELL, KRUG & HALLER B Deputy Sheriff WASHINGTON MUTUAL BANK, FA, F/K/A PNC MORTGAGE CORP. OF AMERICA, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYVANIA Plaintiff V. ANGIE M. WATSON and ROBERT E. WATSON, III Defendant NO. 02-4172 CIVIL ACTION - LAW IN MORTGAGE FORECLOSURE ANSWER TO COMPLAINT IN MORTGAGE FORECLOSURE AND NOW, comes Defendant, Angie Watson by and through her counsel, Karl E. Rominger, Esquire of the Law Firm of Rominger & Bayley and files the within Answer to Complaint in Mortgage Foreclosure and in support thereof sets out the following: 1. Answering Defendant is without sufficient information to admit or deny. 2. Admitted. 3. Admitted. 4. Admitted. 5. Admitted. 6. Admitted. 7. Is denied and proof of the same is demanded at trial. By way of further answer, if any answer is required, answering Defendant is without sufficient information necessary to determine the truth of the assertions in this paragraphs. 8. Answering Defendant is without sufficient information to admit or deny this allegation. 9. Conclusion of law and requires no answer. 10. Admitted. 11. Conclusion of law and requires no answer. WHEREFORE, Defendant demands judgment in her favor and against Plaintiffs. Respectfully submitted, ROMINGER & BAYLEY Karl E. Rominger, Esquire 155 South Hanover Street Carlisle, PA 17013 (717) 241-6070 Supreme Court ID # 81924 Attorney for Defendant Date- Z Dated: WASHINGTON MUTUAL BANK, FA, F/K/A PNC MORTGAGE CORP. OF AMERICA, Attorney for Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYVANIA Plaintiff V. ANGIE M. WATSON and ROBERT E. WATSON, III Defendant NO. 02-4172 CIVIL ACTION - LAW IN MORTGAGE FORECLOSURE VERIFICATION KARL E. ROMINGER, ESQUIRE, states that he is the attorney for, Defendant in this action; that he makes this affidavit as attorney because he has sufficient knowledge or information and belief, based upon his investigation of the matters averred or denied in the foregoing document; and that this statement is made subject to the penalties of 18 Pa. C.S. Pa.C.S. §4904, relating to unsworn falsification to authorities. Date: Id-2 L_ d Karl E. Rominger, Esquire Attorney for Defendant WASHINGTON MUTUAL BANK, FA, F/K/A PNC MORTGAGE CORP. OF AMERICA, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYVANIA Plaintiff V. ANGIE M. WATSON and ROBERT E. WATSON, III Defendant NO. 02-4172 CIVIL ACTION - LAW IN MORTGAGE FORECLOSURE CERTIFICATE OF SERVICE I, Karl E. Rominger, Esquire, attorney for Defendant, do hereby certify that I this day served a copy of the Answer to Complaint in Mortgage Foreclosure upon the following by depositing same in the United States Mail, first class postage prepaid, at Carlisle, Pennsylvania, addressed as follows: Leon P. Haller, Esquire 1719 N. Front Street Harrisburg, PA 17102 fv_22-e7- Karl E. Rominger, Esquire ri WASHINGTON MUTUAL BANK, FA f/k/a PNC MORTGAGE CORP. OF AMERICA, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND CO., PENNSYLVANIA NO. 02-4172 vs. ANGIE M. WATSON and CIVIL ACTION - LAW ROBERT E. WATSON, III, Defendants IN MORTGAGE FORECLOSURE PLAINTIFF'S MOTION FOR SUMMARY JUDGMENT AND NOW, comes the Plaintiff, Washington Mutual Bank, FA f/k/a PNC Mortgage Corp. of America, by its attorneys, Purcell, Krug & Haller, and files the within Motion for Summary Judgment, and avers in support thereof the following: This action in mortgage foreclosure was originally instituted in the Court of Common Pleas of Cumberland County by Complaint filed to No. 02-4172 on September 3, 2002. 2. Defendant, Angie M. Watson filed an Answer to Plaintiffs Complaint on October 22, 2002. 3. In her Answer, the Defendant admitted Paragraphs 2 through 6 and 10 of Plaintiffs Complaint. follows: 4. The Defendant denied Paragraphs 1, 7, 8, 9 and 11 of Plaintiffs Complaint which averred as 1. Plaintiff, WASHINGTON MUTUAL BANK, FA F/K/A F'NC MORTGAGE CORP. OF AMERICA, is a corporation, with an address of P.O. BOX 1169, DEPT. 2665, MILWAUKEE, WISCONSIN 53201. 7. The Mortgage is in default due to the fact that Mortgagors have failed to pay the installment due on May 01, 2002 and all subsequent installments thereon, and the following amounts are due on the Mortgage: UNPAID PRINCIPAL BALANCE $75,716.58 Interest at $16.07 per day From 04/01/2002 To 09/01/2002 (based on contract rate of 7.750%) 2,458.71 Accumulated Late Charges 197.16 Late Charges $28.16 From 05/01/2002 to 09/01/2002 112.64 Escrow Balance 405.48 Attorney's Fee at 5% of Principal Balance 3.785.83 TOTAL $82,686.40 "Together with interest at the per diem rate noted above after September 01, 2002 and other charges and costs to date of Sheriffs Sale. The attorney's fees set forth above are in conformity with the Mortgage documents and Pennsylvania law, and will be collected in the event of a third party purchaser at Sheriffs Sale. If the Mortgage is reinstated prior to the sale, reasonable attorney's fees will be charged that are actually incurred by Plaintiff. 8. No judgment has been entered upon said Mortgage in any jurisdiction. 9. Notice of intention to foreclose and accelerate the loan balance pursuant to Pennsylvania Act No. 6 of 1974 is not required in that the principal balance exceeds $50,000.00. 11. The within Mortgage is insured by the Federal Housing Administration under Title II of the National Housing Act and, as such, is not subject to the provisions of Pennsylvania Act No. 91 of 1983. 5. The Defendant's Answer to Paragraphs 1, 7, 8, 9 and 11 reads as follows: 1. Answering Defendant is without sufficient information to admit or deny. 7. Is denied and proof of the same is demanded at trial. By way of further answer, if any answer is required, answering Defendant is without sufficient information necessary to determine the truth of the assertions in this paragraphs. [sic] 8. Answering Defendant is without sufficient information to admit or deny this allegation. 9. Conclusion of law and requires no answer. 11. Conclusion of law and requires no answer. 6. In her Answer to Paragraph 1, the Defendant denied any knowledge as to the identity of the Plaintiff. 7. In response, the Plaintiff confirms in Paragraphs 1 through 4 of its Summary Judgment Affidavit the identity of the Plaintiff and its standing as the current holder of the Mortgage. 8. Rule 1029 of the Pennsylvania Rules of Civil Procedure governs the proper procedure for a party to respond to a pleading. Rule 1029 reads in pertinent part: a) A responsive pleading shall admit or deny each averment of fact in the preceding pleading or any part thereof to which it is responsive. A party denying only a part of an averment shall specify so much of it as is admitted and shall deny the remainder. Admissions and denials in a responsive pleading shall refer specifically to the paragraph in which the averment admitted or denied is set forth. b) Averments in a pleading to which a responsive pleading is required are admitted when not denied specifically or by necessary implication. A general denial or a demand for proof, except as provided by subdivisions (c) and (e) of this rule, shall have the effect of an admission. 2 C) A statement by a party that after reasonable investigation the party is without knowledge or information sufficient to form a belief as to the truth of an averment shall have the effect of a denial. 9. in response to Paragraph 7, the Defendant denied the fact and amount of default, claiming she was without sufficient information to respond, making no averment of "after reasonable investigation". 10. In its Summary Judgment Affidavit, the Plaintiff verifies that both Defendants are in default and includes in its Affidavit the amounts necessary to both reinstate and pay off the account. 11. The Plaintiff also attaches to its Summary Judgment Affidavit a true and correct copy of the Payment History for the Defendants' account from January 3, 2001 through January 4, 2003 as documentary proof of a date of default of May 1, 2002, showing the last payment credited to the account was on April 24, 2002 for the payment due April 1, 2002. 12. In Paragraph 8, the Defendant denied any knowledge as to whether a judgment has been entered on the Mortgage. 13. A review of the public records of Cumberland County confirms that no judgment has been entered on the Defendants' Mortgage. 14. In Paragraphs 9 and 11, the Defendant denied Plaintiff's compliance with the Notice provisions of Act 6 of 1974 and Act 91 of 1983. 15. Since the Defendants' original Mortgage obligation was greater than $50,000.00, the Plaintiff had no statutory obligation to send Act 6 Notices to either of the Defendants. 16. As to Act 91 Notices, pursuant to 35 P.S. §1680.401(c)(a)(4), the Plaintiff was also not required to send Act 91 Notices because the Mortgage is insured by the Federal Housing Administration and the provisions of Act 91 are not applicable. 17. However, in order to comply with the pre-foreclosure Notice requirements of the Mortgage, the Plaintiff did send Notices to both Defendants dated July 11, 2002, addressed to the property address, which was their last known mailing address at the time. 18. Upon Affidavit filed concurrently with this Motion, the status of the mortgage payments made to and received by Plaintiff is verified and reveals that both Defendants are in default under the terms of the Mortgage and that no cure has been effected. 3 19. The Affidavit further indicates that Plaintiff is the owner and holder of the Mortgage Note dated March 27, 1998 executed by both Defendants in the amount of $78,859.00 for real estate situated at 145 Faith Circle, Carlisle, Pennsylvania 17013, of which both Defendants are the record owners. 20. By reason of the Defendant's foregoing admissions and the documentation of default without an allegation that the default has been cured or documentation thereof, there is no longer a triable issue of fact or law. 21. There being no defense to Plaintiffs Complaint, judgment should be entered in favor of Plaintiff and against the Defendant, Angie M. Watson. WHEREFORE, Plaintiff requests this Honorable Court to enter an Order granting Plaintiffs Motion for Summary Judgment against the Defendant, Angie M. Watson and to enter an in rem judgment in favor of the Plaintiff. Dated:/ 117 103 Respectfully submitted, Jill Wineka, Esquire Att ey I D # 58802 Leon P. Haller, Esquire Attorney ID # 15700 PURCELL, KRUG & HALLER 1719 North Front Street Harrisburg, PA 17102 (717) 234-41.78 Attorneys for Plaintiff 4 CERTIFICATE OF SERVICE I, Barbara A. Shadel, an employee of the law firm of Purcell, Krug & Haller, do hereby certify that I served a true and correct copy of Plaintiffs Motion for Summary Judgment upon the following by depositing same in the United States Mail, First Class Postage, Postage Prepaid, addressed as follows: Karl E. Rominger, Esquire 155 South Hanover Street Carlisle, PA 17013 Attorney for Plaintiff, Angie M. Watson Dated: 1117105 Robert E. Watson, III 145 Faith Circle Carlisle, PA 17013 Pro Se Defendant arbara A. Shadel (fd\wamu\watson\sj motion) PRAECIPE FOR LISTING CASE FOR ARGUMENT (Must be typewritten and submitted in duplicate) TO THE PROTHONOTARY/OF CUMBERLAND COUNTY: Please list the within matter for the next: ? Pre-Trial Argument Court IX Argument Court for March 26, 2003 CAPTION OF CASE (entire caption must be stated in full) Washington Mutual Bank, FA f/k/a PNC Mortgage Corp. of America vs. Anaie M. Watson and Robert F. Watson, III vs. (Plaintiff) (Defendant) No. 02-4172 Civil Term )X 1. State matter to be argued (i. e., plaintiff's motion for new trial, defendant's demurrer to complaint, etc.): Motion for Summary Judgment 2. Identify counsel who will argue case: (a) for plaintiff: Jill M. Wineka, Fsauire (b) for defendant: Karl F. Rominger, Fsa. , Atty for Defendant, Angie M. Watson Robert F. Watson, III, Pro Se Defendant 3. 1 will notify all parties in writing within two days that this case has been listed for argument. 4t?!?J (At neyfor Plaintiff ) Ji M. Wineka, Esa. Dated: 017/03 CERTIFICATE OF SERVICE I, Barbara A. Shadel, an employee of the law firm of Purcell, Krug & Haller, do hereby certify that I served a true and correct copy of a Praecipe for Listing Case for Argument upon the following by depositing same in the United States Mail, First Class Postage, Postage Prepaid, addressed as follows: Karl E. Rominger, Esquire 155 South Hanover Street Carlisle, PA 17013 Attorney for Plaintiff, Angie M. Watson Robert E. Watson, III 145 Faith Circle Carlisle, PA 17013 Pro Se Defendant Barbara A. Shadel Dated: 11176-0' JAN-07-2003 08:48 PURCELL,KRUG & HRLLER 717 233 1149 IN THE COURT OF COMMON PLEAS pN .HING7A MUTT BANK. FA pkla ; CUMBERLAND CO., PENNAYLVANIA NG MUKTGAGE CORP. RP. OF AMaRItCA, NO 02-4172-CIVIL Vs. ANGIE M. WATSON and ROBERT E. WAI'SON, III, Do.fendents CIVIL ACTION - I AW IN MORTGAGE FORECLOSURE STATE OF WISCONSIN ss: Loan No.: 6224903608 APFQAVIT Donna Evans, being duly swom, deposes and says: 1. That I am a Business Analyst of Washington Mutual Bank, FA Vk/a PNG Mortgage Corp, of America (hereinafter "Washington Mutual Bank, FA"), which has a busuress address of P- 0. Box 1169, Dopt. 2665, Milwaukee, Wisconsin 53201, and I have personal knowledge of the facts hereafter set Forth. the 2, TI at in my capacity as a Business Analyst, I have tl i gresp' emgU?g? M. Watson eat RbbarWE. Watson, of Washington Mutual Bank, FA, with respcot to Its murtga0or . III. 31 That Washington Mutual Bank, FA is the current owner and holder of a Note datiud March 21, 1898, executed by AnUif- M. Watson end Rabart F. Watson. III, in rite original amount of $76,859.0n. A true and correct copy of the Note is attached hereto. 4. That said Note is secured by a Mortgam, poyaule to PNC ModgeAe Corp. of America, executed by AnOie M. Watson and Hobert E. Watson, III, which was recorded on March 30, 1990 in Cumh.Aand County Mortgtu,P, Book 1441, Pago 621, PNC KnIgage Corp. of America Is new known as WashbrOlun Mutual Bank, FA. A tn,e and correct dopy of the Mortgage is attached hereto, b. Thatihe property subject to the Mndgago, is beefed at 145 Faith Circle. Carlisle, Pennsylvania 71013, e. That the Vacant owners jr rrrord for plc property art Anoie M. Watson and Rul.irrl E. Watson, III, who a IHwf known eadroes of 145 Faith Circle. Usirlirtla, Pennsylvania 1-M3, A true and rnrredt copy of the Dmpd transferring title to the Defendl*nls. Which was recorded all March 30, 1998 in Deed R4)nk 174, I'ggo d47, is attached hereto, 7. That said Note is now in default, the dur- data of the last Instull,,,cnt heing May 1, 2002- S. That attached hereto is a true mid correct copy of the Payment 1•119tory for the Defendan& account from Ol through ., 1_ q 03 , showing the last payment credited to the Derendanlts' account was on for the payment dup. April 1, 20u2 and conflrrrting a current data of default of May 1, 2002 and %) outstanding princlpal balance of $75.710,58. 9. That the outstanding balance, exc4u5ive of attomeys fees and costs, as of January 31, 2003 is as follows: Present princlpal balance $75,716.58 Interest from 04101102 to 01131/03 4,890.00 Late shames 310.36 Escrow deficit 556.63 Property inspection fees P0. ()r) Pm rata MIP 61.38 P. 02/03 TOTAL TO PAY OFF LOAN $81,614.95 JAN-07-2003 08:48 PURCELL,KRUG & HALLER 717 233 1149 P.03/03 10. Thal intorest acuues frolic the 1" day of FebruarY, 2003, at the rate of 3.6. diem. 11. That the current monthly payment is 5_207 .59. 12. That uie legal fees incurred to data are $2,125,00. 13. That the legal costs incurred to date are S3GR.09. 14. That the amount necessary to reinstate tha mortgage, exclusive of attorney's fees and costs, as of January 31, 2003 is as follows: 2 Pavments from 5/1/02 through 6/1/02 @ $703.88 $1,407.76 7 Pwments from 7/1/02 through 1/1./03 @ $707.59 4,953.13 310.36 Late charges 80 00 Property inspection fees TOTAL TO REINSTATE $6,751.25 1s. That the within Mortgaro- is insured by the Frrleral I•loudin9 Administration under Title II of die National HOUiing Act. 16. That prior tu4kie commenooment of this fnreolooure aotwn, #WPlantitt Gent written Notirr. to Iho Uefendanls dated July 11, 2002, nrldresoed to ore prul aty addrooo. The July 11, 2002 Notloe IndleaWthat their oeocunt was in default, pruyided the amount netrdeddu reinstate their delinquency. and Intbmted?l Defo a Q Act wir oofault was not Timely oured, the Plair dirf would aeoolerawUbalrrnoe duo and file a correct 6epy of the July 11, 2002 Notice is gttacnad her4b. WAEHINGI ON MUTUAL BANK. I-A filda FN MORTGAGE CO ORI? By: Title SWOON to an ubsonbed before me this - day of2003. Notary Public Myenmmission l ?r ` (SEAL) A. 89gc%,? trauv?, ?' 9 ?L 'OUBL,c' ??rnrrrtttmt?`'?? TOTAL P.03 FmC88427.tit (1696x2200x2 titt) 1151 Multistate LENDER'S I«; 02-24-90360 NOTE F$A Ca9e HQ 441:5616238-203 MARCH 27, 1988 [Date] 145 FAITH CIRCLE, CARLISLE, PENNSYLVANIA 17013-8069 [Property Address] 1. PARTIES "Borrower" means each person signing at the end of this Note, and the person's successors and assigns. "Lender" means PNC MORTGAGE CORP. OF AMERICA, AN OHIO CORPORATION and its successors and assigns. 2. BORROWER'S PROMISE TO PAY; INTEREST In return for a loan received from Lender, Borrower promises to pay the principal sum of ------------------------ SEVENTY-EIGHTTHOUSAND EIGHT HUNDRED FIFTY-NINE DOLLARS AND ZERO CENTS--------------------------------------- ----------------------- , --------------------------------------------------- --- Dollars (U.S. $ 78,859.00_____________) plus interest, t0 the order of Lender. Interest will be charged on unpaid principal, from the date of disbursement of the loan proceeds by Lender, at the rate of SEVEN AND THREE FOURTHS-------- percent (------------------7.750 %) per year until the full amount of principal has been paid. 3. PROMISE TO PAY SECURED Borrower's promise to pay is secured by a mortgage, deed of trust or similar security instrument that is dated the same date as this Note and called the "Security Instrument." The Security Instrument protects the Lender from losses which might result if Borrower defaults under this Note. 4. MANNER OF PAYMENT (A) Time Borrowe r shall make a payment of principal and interest to Lender on the first day of each month beginning on MAY 1 , 1998 Any principal and interest rem 2028 , will be due on that date, which is called the "Maturity Da a Wing on the first day of APRIL (B) Place Payment shall be made at 75 NORTH FAIRWAY DRIVE, VERNON HILLS, ILLINOIS 60061 writing by notice to Borrower. or at such place as Lender may designate in (C) Amount Each monthly payment of principal and interest will be in the amount of U.S. $ 564.96-------------------- This amount will be part of a larger monthly payment required by the Security Instrument, that shall be applied to principal, interest and other items in the order described in the Security Instrument. (D) Allongeto this Note for payment adjustments If an allonge providing for payment adjustments is executed by Borrower together with this Note, the covenants of the allonge shall be incorporated into and shall amend and supplement the covenants of this Note as if the allonge were apart of this Note. [Check applicable box] Q Graduated Payment Allonge Q Growing Equity Allonge Q Other [specify] 5. BORROWER'S RIGHT TO PREPAY Borrower has the right to pay the debt evidenced by this Note, in whole or in part, without charge or penalty, on the first day of any month. Lender shall accept prepayment on other days provided that borrower pays interest on the amount prepaid for the remainder of the month to the extent required by Lender and permitted by regulations of the Secretary. If PHA Multistate Fixed Rate Note - IW95 4%-'R 1"011 XC30500AAA (M).03 1196 YMP MORTGAGE FORMS - (800)521-7291 >,". 1 e 2 1n)ti81s:L?"" ' °' If I?I'9@t ?I I II Inl F=88427.tit (1696x2200x2 titt) L16J Borrower makes a partial prepayment, there will be no changes in the due date or in the amount of the monthly payment unless Lender agrees in writing to those changes. 6. BORROWER'S FAILURE TO PAY (A) Late Charge for Overdue Payments If Lender has not received the full monthly payment required by the Security Instrument, as described in Paragraph 4(C) of this Note, by the end of fifteen calendar days after the payment is due, Lender may collect a late charge in the amount of FOUR---------------------------------------- percent (------------------- 4.000 %) of the overdue amount of each payment. (B) Default If Borrower defaults by failing to pay in full any monthly payment, then Lender may, except as limited by regulations of the Secretary in the case of payment defaults, require immediate payment in full of the principal balance remaining due and all accrued interest. Lender may choose not to exercise this option without waiving its rights in the event of any subsequent default. In many circumstances regulations issued by the Secretary will limit Lender's rights to require immediate payment in full in the case of payment defaults. This Note does not authorize acceleration when not permitted by HUD regulations. As used in this Note, "Secretary" means the Secretary of Housing and Urban Development or his or her designee. (C) Payment of Costs and Expenses If Lender has required immediate payment in full, as described above, Lender may require Borrower to pay costs and expenses including reasonable and customary attorneys' fees for enforcing this Note to the extent not prohibited by applicable law. Such fees and costs shall bear interest from the date of disbursement at the same rate as the principal of this Note. 7. WAIVERS Borrower and any other person who has obligations under this Note waive the rights of presentment and notice of dishonor. "Presentment" means the right to require Lender to demand payment of amounts due. "Notice of dishonor" means the right to require Lender to give notice to other persons that amounts due have not been paid. 8. GIVING OF NOTICES Unless applicable law requires a different method, any notice that must be given to Borrower under this Note will be given by delivering it or by mailing it by first class mail to Borrower at the property address above or at a different address if Borrower has given Lender a notice of Borrower's different address. Any notice that must be given to Lender under this Note will be given by first class mail to Lender at the address stated in Paragraph 4(B) or at a different address if Borrower is given a notice of that different address. 9. OBLIGATIONS OF PERSONS UNDER THIS NOTE If more than one person signs this Note, each person is fully and personally obligated to keep all of the promises made in this Note, including the promise to pay the full amount owed. Any person who is a guarantor, surety or endorser of this Note is also obligated to do these things. Any person who takes over these obligations, including the obligations of a guarantor, surety or endorser of this Note, is also obligated to keep all of the promises made in this Note. Lender may enforce its rights under this Note against each person individually or against all signatories together. Any one person signing this Note may be required to pay all of the amounts owed under this Note. BY SIGNING BELOW, Borrower accepts and agrees to the terms and covenants contained in this Note. .s?/a ,/ (Seal ) ROBERT E WATSON III -Borrower (Seal) -14 GIE N ATSON -Borrower (ML- XC3o50oAA8(W.031/90 _ (Seal) -Borrower _ (Seal) -Borrower (Seal) -Borrower (Seal) -Borrower pAY TO THE ORDER OF. (Seal) WIT14OUT REGOURSt -Borrower PNC rtgage Gorp. of America (Seal) orrower at. SacrotWy Palo 2 of 2 mil E. waasei ....... a ,. .. !u_auo coon T? - - PNC Mortgage Cory), of America '98 mi ,((I ?r( 11 E3 75 North Fairway Drive Document Operations - S 1-51175-03-A Vernon Ilills, IL 60061 PREPARED BY: MARGARET HUMPHREYS BETHEL PARK, PA 15102 Parcel Number: 29-14-0868-078 (Space Above This Line l°ur Recording Datal Commonwealth of Pennsylvania MORTGAGE PHA Case No. 441:5616238-203 LENDER'S s 02-24-90360 ll ]IS Nf012.PCAG13 ("Security Instrument") is given on MARCH 27, 1998 'I lie Mortgagor is ROBERT E WATSON 111 AND ANGIE M WATSON. MARRIED ("Burrower").'Phis Security Instrument is given to INC MORTGAGE CORP. OF AMERICA which is organized and existing under the laws of THE STATE OF OHIO and whose address is 75 NORTH FAIRWAY DRIVE, VERNON HILLS, ILLINOIS 60061 ("I-ender"). ISorrower owes Lender the principal sum of SEVENTY-EIGHT THOUSAND EIGHT HUNDRED FIFTY-NINE DOLLARS AND ZERO CENTS ------------------------------ ------------------------------------------------------------- IJollars (U.S.S 78.859.00------------- ). 'I'bis debt is evidenced by Borrower's note dated the same date as this Security Instrument ("Note"), which provides for monthly payments, with the full debt, if not paid earlier, due and payable on APRIL 1, 2028 . 'I'his Security Instrument secures to Lender: (a) the repayment of the debt evidenced by the Note, with interest, and all renewals, extensions and modifications of the Note; (b) the payment of all other sums, with interest, advanced under paragraph 7 to protect the security of this Security Instrument and (c) the performance of Borrower's covenants and agreements under this Security 17IA Pennsylvania Mortgage - 4196 -4RIPA) meoa .<Ia1isoA..11A1 ,).)as •„ I Me MORTGAGE FORMS 19001e1e *T IIIIIIIIIVIII III IIIIII IIIIIIII III) nooK1441liAGE .622 Instrument and the Note. Por this purpose, Borrower does hereby mortgage, grant and convey to the I,ender the following described property located in CUM8ERLAN0 County, Pennsylvania: which has the address of 145 FAITH CIRCLE, CARLISLE Istree3, City). Pennsylvania 17013-8869 IZ,G,del ("Property Address"); FOGIE'N I Ai WYFl I all the improvements now or hereafter erected on the property, and all casements, appurtenances and fixtures now or hereaftera part of the property. All replacements and additions shall also be covered by this Security Instrument. All of the foregoing is referred to in this Security Instrument as the "Property,' 1101MOWIiR L'OVIiNAN'I'S that Borrower is lawfully seized of the estate hereby conveyed and has the right to mortgage, grant and convey the Property and that the Property is unencumbered, except for encumbrances of record. Borrower warrants and will defend generally the title to the Property against all claims and demands, subject to any encumbrances of record. TI11S SILCURITY INSTRUMeM' combines uniform covenants for national use and nonuniform covenants with limited variations by jurisdiction to constitute a uniform security instrument covering real property. Borrower and Lender covenant and agree as follows: UNIP•O12M COVIiNANTS. 1. Payment of Principal. Interest and late Charge. Borrower shall pay when due the principal of, and i nterest on, the debt evidenced by the Note and late charges due under the Note. 2. Monthly Payment of "faxes, Insurance and Other Charges. Borrower shall include in each monthly payment, together with tine principal and interest as set forth in the Note and any late charges, a sum for (a) taxes and special assessments levied or to be levied against the property, (b) leasehold payments or ground rents on the Property, and (c) premiums for insurance required under paragraph 4. In any year in which the lender must pay a mortgage insurance premium to the Secretary of Iloosing and Urban Development ("Secretary"). or in any year in which such premium would have been required if Lender still held the Security Instrument, each monthly payment shall also include either: (i) a sum for the annual mortgage insurance premium to be paid by Lender to the Secretary, or (ii) a monthly charge instead of a mortgage insurance premium if this Security Instrument is held by the Secretary, in a reasonable amount to be determined by the Secretary. Except for the monthly charge by the Secretary, these items are called "escrow Items" and the sums paid to Lender are called "escrow Ponds." Lender may, at any time, collect and hold amounts for 13scrow Items in an aggregate amount not to exceed the maximum amount that may be required for Borrower's escrow account under the 12eal lstate Settlement Procedures Act of 1974, 12 U.S.C. Section 2601 e7 seq. and implementing regulations, 24 CPR fart 3500, as they may be amended from time to time ("ReSPA"), except that the cushion or reserve permitted by IWSPA for unanticipated disbursements or disbursements before the Borrower's payments are available in the account may not be based on amounts due for the mortgage insurance premium. OO .13 ./GB (M-4R( RIPAI eood441 FAG1.623 If the amounts held by Lender for Escrow Items exceed the amounts permitted to be held by RESPA. Lender shall account to Borrower for the excess funds as required by RESPA. If the amounts of funds held by Lender at any time is not sufficient to pay the Escrow Items when due, Lender may notify the Borrower and require Borrower to make up the shortage as permitted by R SPA. The Escrow Funds are pledged as additional security for all sums secured by this Security Instrument. If Borrower tenders to Lender the full payment of all such sums, Borrower's account shall be credited with the balance remaining for all installment items (a), (b), and (c) and any mortgage insurance premium installment that Lender has not become obligated to pay to the Secretary, and Lender shall promptly refund any excess funds to Borrower. Immediately prior to a foreclosure sale of the Property or its acquisition by Lender. Borrower's account shall be credited with any balance remaining for all installments for items (a), (b), and (c). 3. Application of Payments. All payments tinder paragraphs I and 2 shall he applied by Lender as follows: First, to the mortgage insurance premium to be paid by Lender to the Secretary or to the monthly charge by the Secretary instead of the monthly mortgage insurance premium; Second, to any taxes, special assessments, leasehold payments or ground rents, and fire, flood and other hazard insurance premiums, as required; Third, to interest due under the Note; Fourth, to amortization of the principal of the Note; and Fifth, to late charges due under the Note. 4. Fire, Flood and Other Hazard Insurance. Borrower shall insure all improvements on the Property, whether now in existence or subsequently erected, against any hazards, casualties, and contingencies, ineluding fire, for which Lender requires insurance. 'I big insurance shall he maintained in the amounts and for the periods that Lender requires. Burrower shall also insure all improvements un the Property, whether now in existence or subsequently erected, against loss by floods to the extent required by the Secretary. All insurance shall be carried with companies approved by fender. The insurance policies and any renewals shall be held by Lender and shall include loss payable clauses in favor of, and in a form acceptable to, Lender. In the event of loss, Borrower shall give Lender immediate notice by mail. Lender may make proof of loss if not made promptly by Borrower. Each insurance company concerned is hereby authorized and directed to make payment for such loss directly to Lender, instead of to Borrower and to Lender jointly. All or any part of the insurance proceeds may be applied by Lender, at its option, either (a) to the reduction of the indebtedness under the Note and this Security Instrument, first to any delinquent amounts applied in the order in paragraph 3, and then to prepayment of principal, or (b) to the restoration or repair of the damaged Property. Any application of the proceeds to the principal shall not extend or postpone the due date of the monthly payments which are referred to in paragraph 2, or change the amount of such payments. Any excess insurance proceeds over an amount required to pay all outstanding indebtedness under the Note and this Security Instrument steal l be paid to the entity legally entitled thereto. In the event of foreclosure of this Security Instrument or other transfer of title to the Property that extinguishes the indebtedness, all right, title and interest of Borrower in and to insurance policies in force shall pass to the purchaser. 5. Occupancy, Preservation, Maintenance and Protection of the Property; Iorrower's Loan Application; Leascholds. Borrower shall occupy, establish, and use the Property an 1orrower's principal residence ttithin sixty days after the exeCUhnn Of this SCCUrity Instrument (or within sixty days of a later sale or transferof the Property) and shall continue to occupy the Property as Borrower's principal residence for at least one year after the date of occupancy, unless Lender determines that requirement will cause undue hardship for Burrower, or unless extenuating circumstances exist which are beyond Borrower's control. Borrower shall notify lender of any extenuating circumstances. Borrower shall no[ commit waste or destroy, damage or substantially change the Property or allow the property to deteriorate, reasonable wear and tear excepted. Lender may inspect the Property if the Property is vacant or abandoned or the loan is in defa Ult. Lender may take reasonable action to protect and preserve such vacant or abandoned Property. Borrower shall also be in default if Borrower, during the loan application process, gave materially false or inaccurate information or statements to Lender (or failed to provide Lender with any material information) in connection with the loan -4nIPA1 ism.. •c,ocao..ec vu .u .tae „ , . a . a ? 1c11eir ??y.?tk?/ souk 1441 PACE 3624 evidenced by the Note, including, but nut limited to, representations concerning Borrower's occupancy of the property as a principal residence. If this Security Instrument is on a leasehold, Borrower shall comply with the provisions of the lease. If Borrower acquires fee title to the Property, the leasehold and fee title shall not be merged unless Lender agrees to the merger in writing. (. Condemnation. The proceeds of any award or claim for damages, direct or consequential, in connection with any condemnation or other taking of any part of the Property, or for conveyance in place of condemnation, are hereby assigned and shall be paid to lender to the extent of the full amount of the indebtedness that remains unpaid under the Note and this Security Instrument. Lender shall apply such proceeds to the reduction of the indebtedness under the Note and this Security Instrument, first to any delinquent amounts applied in the order provided in paragraph 3, and then to prepayment of principal. Any application of the proceeds to the principal shall not extend or postpone the due date of the monthly payments, which are referred to in paragraph 2, or change the amount of such payments. Any excess proceeds over an amount required to pay all outstanding indebtedness under the Note and this Security Instrument shall be paid to the entity legally entitled thereto. 7. Charges to Borrower and Protection of Lender's Rights in the Property. Borrower shall pay all governmental or municipal charges, fines and impositions that are not included in paragraph 2. Burrower shall pay these obligations on time directly to the entity which is owed the payment. If failure to pay would adversely affect Lender's interest in the property, upon Lender's request Borrower shall promptly furnish to bender receipts evidencing these payments. If Borrower fails to make these payments or the payments required by paragraph 2, or fails to perform any other covenants and agreements contained in this Security Instrument, or there is a legal proceeding that may significantly affect Lender's rights in the Property (such as a proceeding in bankruptcy, for condemnation or to enforce laws or regulations), then Lender may do and pay whatever is necessary to protect the value or the Property and Lender's rights in the property, including payment of taxes, hazard insurance and other items mentioned in paragraph 2. Any amounts disbursed by Lender under this paragraph shall become an additional debt of Borrower and be secured by this Security Instrument. 'I'hese amounts shall bear interest from the date of disbursement, at the Note rate, and at the option of Lender, shall be immediately due and payable. Borrower shall promptly discharge any lien which has priority over this Security Instrument unless Borrower: (a) agrees in writing to the payment of the obligation secured by the lien in a manner acceptable to Lender; (b) contests in good faith the lien by, or defends against enforcement of the lien in, legal proceedings which in the Lender's opinion operate to prevent the enforcement of the lien; or (o) secures from the holder of the lien an agreement satisfactory to Lender subordinating the lien to this Security Instrument. If bender determines that any part of the Property is subject to a lien which may attain priority over this Security Instrument, Lender may give Borrower a notice identifying the lien. Borrower shall satisfy the lien or take one or more of the actions set forth above within 10 days of the giving of notice. a. Pees. Lender may collect fees and charges authorized by the Secretary. 9. Grounds for Acceleration or Debt. (a) Default. Lender may, except as limited by regulations issued by the Secretary, in the case or payment defaults, require immediate payment in full of all sums secured by this Security Instrument if: (i) Borrower defaults by failing to pay in full any monthly payment required by this Security Instrument prior to or on the duedate of the next monthly payment, or (ii) Borrower defaults by failing, for a period of thirty days, to perform any other obligations contained in this Security Instrument. (b) Sale Without Credit Approval. Lender shall, if permitted by applicable law (including Section 341(d) of the Garn-St. Germain Depository Institutions Act of 1982, 12 U.S.C. 1701j-3(d)) and with the prior approval of the Secretary, require immediate payment in full of all sums secured by this Security Instrument if: -4flIPA1 ieewl ' 9? e, B Ini, iela HuxiMPacE 625 M All or part of the Property, or a beneficial interest in a trust owning all or part of the Property, is sold or otherwise transferred (other than by devise or descent), and (ii) 'I lie Property is not occupied by the purchaser or grantee as his or her principal residence, or the purchaser or grantee does so occupy the Property but his or her credit has not been approved in accordance with the requirements of the Secretary. (c) No Waiver. If circumstances occur that would permit Lender to require immediate payment in full, but Lender does not require such payments, Lender does not waive its rights with respect to subsequent events. (d) Regulations of IIUD Secretary. In many circumstances regulations issued by the Secretary will limit Lender's rights, in the case of payment defaults, to require immediate payment in full and foreclose if not paid. This Security Instrument does not authorize acceleration or foreclosure it not permitted by regulations of the Secretary. (e) Mortgage Not Insured. Borrower agrees that if this Security Instrument and the Note are not determined to be eligible for insurance under the National Housing Act within 60 days from the date hereof, Lender may, at its option, require immediate payment in full of all sums secured by this Security Instrument. A written statement of any authorized agent of the Secretary dated subsequent to 60 days from the date hereof, declining to insure this Security Instrument and the Note, shall be deemed conclusive proof of such ineligibility. Notwithstanding the foregoing, this option may not he exercised by Lender when the unavailability of insurance is solely due to Lender's failure to remit a mortgage insurance premium to the Secretary. 10. Reinstatement. Borrower has a right to be reirtstrited if lender has required immediate payment in full because of Borrower's failure to pay an amount due under the Note or this Security Instrument. This right applies even after foreclosure proceedings are instituted. To reinstate the Security Instrument, Borrower shall tender in a lump sum all amounts required to bring Borrower's account current including, to the extent they are obligations of Borrower under this Security Instrument, foreclosure costs and reasonable and customary attorneys' fees and expenses properly associated with the foreclosure proceeding. Upon reinstatement by Borrower, this Security Instrument and the ohligations that it secures shall remain in effect as if lender lead not required immediate payment in full. However, lender is not required to permit reinstatement if: (i) Lender has accepted reinstatement after the commencement of foreclosure proceedings within two years immediately preceding the commencement of a current foreclosure proceeding, (ii) reinstatement will preclude foreclosure on different grounds in the future, or (iii) reinstatement will adversely affect the priority of the lien created by this Security Instrument. 11. Borrower Not Released; Forbearance IIy Lender Not a Waiver. Extension of the time of payment or modification of amortization of the sums secured by this Security Instrument granted by Lender to any successor in interest of Borrower shall not operate to release the liability of the original Borrower or Borrower's successor in interest. Lender shall not be required to commence proceedings against any successor in interest or refuse to extend time for payment or otherwise modify amortization of the sums secured by this Security Instrument by reason of any demand made by the original Borrower or Borrower's successors in interest. Any forbearance by lender in exercising any right or remedy shall not be a waiver of or preclude the exercise of any right or remedy. 12. Successors and Assigns Bound; Joint and Several Liability; Co-Signers. The covenants and agreements of this Security Instrument shall bind and benefit the successors and assigns of Lender and Borrower, subject to the provisions of paragraph 9(b). Borrower's covenants and agreements shall be joint and sereral. Any Borrower who co-signs this Security Instrument but does not execute the Note: (a) is co-signing this Security Instrument only to mortgage, grant and convey that Borrower's interest in the Property under the terms of this Security Instrument: (b) is not personally obligated to pay the sums secured by this Security Instrument; and (c) agrees that lender and any other Borrower may agree to extend, modify, forbear or make any aecom modations with regard to the terms of this Security Instrument or the Note without that Borrower's consent. 13. Notices. Any notice to Borrower provided for in this Security Instrument shall be given by delivering it or by mailing it by first class mail unless applicable law requires use of another method. The notice shall be directed to the Property Address or any other address Borrower designates by notice to Lender. osn„E le u.o uc ®y 4RIPA1 m ao P.I. s m a iniueia L rY/ eook1441?age 626 Any notice to Lender shall be given by first class mail to Lender's address staled heroin or any address Lender designates by notice to Borrower. Any notice provided for in this Security Instrument shall be deemed to have been given to Borrower or Lender when given as provided in this paragraph. 14. Governing Law; Severability.This Security Instrument shall be governed by Federal law and the law of the jurisdiction in which the Property is located. In the event that any provision or clause of this Security Instrument or the Note conflicts with applicable law, such conflict shall not affect other provisions of this Security Instrument or the Note which can be given effect without the conflicting provision. 'Po this end the provisions of this Security Instrument and the Note are declared to he severable. 15. Borrower's Copy, Borrower shall be given one conformed copy of the Note and of this Security Instrument. 16. Hazardous Substances. Borrower shall not cause or permit the presence, use, disposal, storage, or release of any I lazardous Substances on or in the property. Borrower shall not do, nor allow anyone else to do, anything affecting the Property that is in violation of any Environmental Law. The preceding two sentences shall not apply to the presence, use, or storage on the Property of small quantities of I lazardous Substances that are generally recognized to be appropriate to normal residential uses and to maintenance of the property. Borrower shall promptly give Lender written notice of any investigation, claim, demand, lawsuit or other action by any governmental or regulatory agency or private party involving the property and any Ilazardous Substance or Environmental Law of which Borrower has actual knowledge. If Borrower learns, or is notified by any governmental or regulatory authority, that any removal or other remediation of any f lazardous Substances affecting the property is necessary, Borrower shall promptly take all necessary remedial actions in accordance with Environmental Law. As used in this paragraph 10, "l lazardous Substances" are those substances defined as toxic or hazardous substances by Environmental Law and the following substances: gasoline, kerosene, other flammable or toxic petroleum products, toxic pesticides and herbicides, volatile solvents, materials containing asbestos or formaldehyde, and radioactive materials. As used in this paragraph 16, "Environmental Law" means federal laws and laws of the jurisdiction where the Property is located that relate to health, safety or environmental protection. NON-LJNI1701ZNI COVENAN"I'S. Borrower and Lender further covenant and agree as follows: 17. Assignment of Rents. Borrower unconditionally assigns and transfers to Lender all the rents and revenues of the Property. Borrower authorizes Lender or Lender's agents to collect the rents and revenues and hereby directs each tenant of the Property to pay the rents to Lender or Lender's agents. I lowever, prior to Londe{s notice to Burrower of Borrower's breach or any covenant or agreement in the Security Instrument, Burrower shall collect and receive all rents and revenues of the Property as trustee for the benefit of Lender and Borrower. 'Phis assignment of rents constitutes an absolute assignment and not an assignment for additional security only. ' If Lender gives notice of breach to Borrower: (a) all rents received by Borrower shall be held by Borrower as trustee for benefit of Lender only, to be applied to the sums secured by the Security Instrument; (b) Lender shall be entitled to collect and receive all of the rents of the Property; and (c) cacti tenant of tiro Property shall pay all rents due and unpaid to Lender or Lender's agent on Lender's written demand to die tenant. Borrower has not executed any prior assignment of the rents and has not and will not perform any act that would prevent Lender from exercising its rights under this paragraph 17. Lender shall not be required to enter upon, take control of or maintain the Property before or after giving notice of breach to Borrower. I lowever, Lender or a judicially appointed receiver may do so at any time there is a breach. Any application of rents shall not cure or waive any default or invalidate any other right or remedy of Lender. This assignment of rents of the Property shall terminate when the debt secured by the Security Instrument is paid in full. 0050/..1 Innl ./] Y/ l=o-4RIPA1 Joao.. a .y. .r a Iniuel. nod 1991 racE 627 IA. Foreclosure Procedure. If Lender requires immediate payment in full under paragraph 9, Lender may foreclose this Security Instrument by judicial proceeding. Lender shall be entitled to collect all expenses incurred in pursuing the remedies provided in this paragraph 18, including, but not limited to, attorneys' fees and costs of titleevidence. If the Lender's interest in this Security Instrument is held by the Secretary and the Secretary requires immediate payment in full under Paragraph 9, the Secretary may invoke the nonjudicial power of sale provided in the Single Family Mortgage Foreclosure Act or 1994 ("Act") (12 U.S.C. 3751 et seq. ) by requesting a foreclosure commissioner designated under the Act to commence foreclosure and to sell the Property as provided in the Act. Nothing in the preceding sentence shall deprive the Secretary of any rights otherwise available to a Lender under this Paragraph Ia or applicable law. 19. Release. Upon payment of all sums secured by this Security Instrument, this Security Instrument and the estate conveyed shall terminate and become void. After such occurrence, Lender shall discharge this Security Instrument without charge to Borrower. Borrower shall pay any recordation costs. 20. Waivers. Borrower, to the extent permitted by applicable law, waives and releases any error or defects in proceedings to enforce this Security Instrument, and hereby waives the benefit of any present or future laws providing for stay of execution, extension of time, exemption from attachment, levy and sale, and homestead exemption. 21. Reinstatement Period. Borrower's time to reinstate provided in paragraph 10 shall extend u one hour prior to the commencement of bidding at a sherirr's sale or other sale pursuant to this Security Instrument. 22. Purchase Money Mortgage. If any of the debt secured by this Security Instrument is lent to Borrower to acquire title to the Property, this Security Instrument shall be a purchase money mortgage. 23. Interest Rate After Judgment. Borrower agrees that the interest rate payable after a judgment is entered on the Note or in an action of mortgage foreclosure shall be the rate payable from time to time under the Note. 24. Riders to this Security Instrument. If one or more riders are executed by Borrower and recorded together with this Security Instrument, the covenants or each such rider shall he incorporated into and shall amend and supplement the covenants and agreements of this Security Instrument as if the rider(s) were a part of this Security Instrument. [Check applicable box(es)). Condominium Rider Growing Equity Rider OOther [specify) Planned Unit Development Rider g Graduated Payment Rider ace -9RIPAI meo" P,a. r., a initinc? Bood4UPAGE 628 II}' SIGNING BELO\V, Borrower accepts and agrees to the terms contained in this Security Instrument and in any rider(s) executed by Borrower and recorded with it. es: I / 1?wCi? C, r"-.?'--+??- (Seal) ROBERT E WATSON III -Burrower (Seal) -Ilorrnwer (Seal) -hurruwur (Seal) -Ilor rower /?2';'P' A-dA'L, (Seal) AN61E D WAMN -Bor,... (Seal) ILrrn,..er _ (Seal) -I Iur rr,.. er _ (Seal) -IL,rr?,wr.r Cert ificate or it d Ina"' / 1. G It n Ia 1'11. Wef G i n Y7a?Nor do hereby certify that the correct address of t tc within-namedf aqder is r6 Fa t r wo+,' ?Y ve [r n o.v .Al, )s t01 6Uo (a / \Vitness my hand this a 141 day of YVI rM CGS lc(Q®B , A ; -nt of Lender COI AIONII'IiA I: I'll OF PENNSYLVANIA, County ss: On this, the ?JJf'el day of /?') a--c-?/ y9Y? before me, the undersigned officer, personally peared Ger,z e. Zt1afsoAd--tWE 4yr? known to me (or satisfactorily proven) to be the persons whose name S QnP subscribed to the within instrument and acknowledged that , ` 'L 1; ,`•.., executed the same for the purposes herein contained. q•,F.. pl c:; :\??' IN NI"1'NISS \VI IIZRHOF, I hereunto set my hand and official seal. bly Commission Expires: Naadal Seal / Glenda ant Public _ u Camp Hal l Sara, Cumueeland rland County y hfy COmnnssicn E.pires Dec. 27, 1998 -•!•'' c roosoe.a r.u .n er ? d Titu of Officer -4RIPA) rvvovi v.n v .r e BOUK Wi PAh•IE 629 EXHIBIT "A" ALL that certain tract or parcel of land, with the buildings and improvements thereon erected, SITUATE in the Township of North Middleton, County of Cumberland, Commonwealth of Pennsylvania and described in accordance with a Plan of Property made by Larry V. Neidlinger, dated February 28, 1980, as follows, to wit: BEGINNING at an iron pin on the Westerly side of Faith Circle (60 feet wide), at a comer of Lot No. 156; thence extending from said point of beginning and along Lot No. 156; North 89 degrees 34 minutes 18 seconds West, the distance of 357.90 feet to a point, in line of lands of Kingsbrook Section II; thence extending along the last mentioned lands, the two (2) following courses and distances, (I) North 25 degrees 25 minutes 33 seconds West, the distance of 15.77 feet to a point, and (2) North 43 degrees 30 minutes 42 seconds East, the distance of 49.02 feet to a point, at a comer of Lot No. 108; thence extending along Lot No. 108, South 89 degrees 34 minutes 18 seconds East, the distance Of,3j1.29feet to an iron pin on the Westerly side of Faith Circle; thence extending along the said side of Faith Circle, South 00 degrees 25 minutes 42 seconds East, the distance of 50.00 feet to the first mentioned point and place of BEGINNING. BEING known and numbered as 145 Faith Circle BEING shown as Lot Nos. 109 and 156-B on the plan of Kingsbrook, as recorded in Plan Books: 27 at Page 3 and 36 at Page 19. UNDER AND SUBJECT, NEVERTHELESS, to all rights of way, easements, restrictions and/or conditions of record. BEING the same premises which Ernest A. Hoffstetter and Muriel Hoffstetter, his wife, by deed of even date and about to be recorded herewith, granted and conveyed unto Robert E. Watson, III and Angie M. Watson, the Mortgagors herein. St.u,: o. Pennsylvania t l:ounry of Cumberland) 8r; iiccurued it arc Office for i' :r7vdin J of Gearis V. and U r r rberlnrr V p_ vrim s my ll carli. f00H"(MPACE 630 corder SER1 5224903608 CUSTOMER SERVICE INV A91/002 01/06/03 11:18:14 ROBERT E WATSONIII 158-82-5392 1C TYPE F.H.A. MAN F ANGIE M WATSON 177-60-4931 IR 7.75000 BR 00 717-486-3160 145 FAITH CIRCLE CARLISLE PA 17013-8869 B 301-863-6526 _ < RCVD FIRST AMERICAN INV/01516310 THE INVOICE IS >: 12/23/02 ---- "HIST---------------------- * LOAN HISTORY *--------------------------(MORE) PROC-DT DUE-DT TRAN TRAN-DESCRIPTION TRAM-EFFECTIVE-DATE TRAN-AMT PRINCIPAL INTEREST ESCROW AMOUNT/CD/DESCRIPTION 01-04-03 05-02 161 ESCROW ADVANCE 30.69 0.00 0.00 30.69 01-04-03 04-03 310 MORTGAGE INSURANCE DISBURSEMENT 30.69- 0.00 0.00 30.69- PAYEE = RBP 556.63- 01-02-03 05-02 168 REPAY OF ESCROW ADVANCE 0.00 0.00 0.00 2.30- 2.30 ADVANCE REFUND 12-31-02 05-02 160 INTEREST ON ESCROW DEPOSIT 2.30 0.00 0.00 2.30 525.94- 12-16-02 05-02 152 LATE CHARGE ASSESSMENT 0.00 0.00 0.00 0.00 28.30-1 LATE CHARGE ---* PF2 FOR ADDL MESSAGES *--------------------------------------------------- LOAN IS ACTIVE FORECLOSURE LOAN IS IN FORECLOSURE, F/C STOP = 3 FULL SETTLEMENT 09/11/02 LOAN PAST DUE 009 MONTHS 037 DAYS PAST PROJECTED LEGAL DATE PROCESSING NOTES ARE PRESENT SER1 5224903608 CUSTOMER SERVICE INV A91/002 01/06/03 11:18:14 ROBERT E WATSONIII 158-82-5392 1C TYPE F.H.A. MAN F ANGIE M WATSON 177-60-4931 IR 7.75000 BR 00 717-486-3160 145 FAITH CIRCLE CARLISLE PA 17013-8869 B 301-863-6526 _ < RCVD FIRST AMERICAN INV/01516310 THE INVOICE IS >: 12/23/02 ---- HIST---------------------- * LOAN HISTORY *--------------------------(MORE) PROC-DT DUE-DT TRAN TRAN-DESCRIPTION TRAN-EFFECTIVE-DATE TRAN-AMT PRINCIPAL INTEREST ESCROW AMOUNT/CD/DESCRIPTION 12-06-02 05-02 161 ESCROW ADVANCE 30.69 0.00 0.00 30.69 12-06-02 04-03 310 MORTGAGE INSURANCE DISBURSEMENT 30.69- 0.00 0.00 30.69- PAYEE = RBP 528.24- 12-03-02 00-00 631 PROPERTY PRESERVATION 20.00 0.00 0.00 0.00 20.00 MTGR REC CORP ADV BA 11-16-02 05-02 152 LATE CHARGE ASSESSMENT 0.00 0.00 0.00 0.00 28.30-1 LATE CHARGE 11-08-02 00-00 631 PROPERTY PRESERVATION 20.00 0.00 0.00 0.00 20.00 MTGR REC CORP ADV BA ---* PF2 FOR ADDL MESSAGES *--------------------------------------------------- LOAN IS ACTIVE FORECLOSURE LOAN IS IN FORECLOSURE, F/C STOP = 3 FULL SETTLEMENT 09/11/02 LOAN PAST DUE 009 MONTHS 037 DAYS PAST PROJECTED LEGAL DATE PROCESSING NOTES ARE PRESENT SERI 5224903608 CUSTOMER SERVICE INV A91/002 01/06/03 11:18:14 ROBERT E WATSONIII 158-82-5392 1C TYPE F.H.A. MAN F ANGIE M WATSON 177-60-4931 IR 7.75000 BR 00 717-486-3160 145 FAITH CIRCLE CARLISLE PA 17013-8869 B 301-863-6526 _ < RCVD FIRST AMERICAN INV/01516310 THE INVOICE IS >: 12/23/02 ---- HIST---------------------- * LOAN HISTORY *--------------------------(MORE) PROC-DT DUE-DT TRAN TRAN-DESCRIPTION TRAN-EFFECTIVE-DATE TRAN-AMT PRINCIPAL INTEREST ESCROW AMOUNT/CD/DESCRIPTION 11-06-02 05-02 161 ESCROW ADVANCE 30.69 0.00 0.00 30.69 11-06-02 04-03 310 MORTGAGE INSURANCE DISBURSEMENT 30.69- 0.00 0.00 30.69- PAYEE = RBP 497.55- 10-31-02 00-00 633 MISC FORECLOSURE AND BANKRUPTCY EXPENSES 5.00 0.00 0.00 0.00 5.00 MTGR REC CORP ADV BA 10-31-02 00-00 633 MISC FORECLOSURE AND BANKRUPTCY EXPENSES 35.00 0.00 0.00 0.00 35.00 MTGR REC CORP ADV BA 10-16-02 05-02 152 LATE CHARGE ASSESSMENT 0.00 0.00 0.00 0.00 28.30-1 LATE CHARGE ----------------------------------------- ---* PF2 FOR ADDL MESSAGES *---------- LOAN IS ACTIVE FORECLOSURE LOAN IS IN FORECLOSURE, F/C STOP = 3 FULL SETTLEMENT 09/11/02 LOAN PAST DUE 009 MONTHS 037 DAYS PAST PROJECTED LEGAL DATE PROCESSING NOTES ARE PRESENT SER1 5224903608 CUSTOMER SERVICE INV A91/002 01/06/03 11:18:14 ROBERT E WATSONIII 158-82-5392 1C TYPE F.H.A. MAN F ANGIE M WATSON 177-60-4931 IR 7.75000 BR 00 717-486-3160 145 FAITH CIRCLE CARLISLE PA 17013-8869 B 301-863-6526 _ < RCVD FIRST AMERICAN INV/01516310 THE INVOICE IS >: 12/23/02 ---- "HIST---------------------- * LOAN HISTORY *--------------------------(MORE) PROC-DT DUE-DT TRAM TRAM-DESCRIPTION TRAM-EFFECTIVE-DATE TRAN-AMT PRINCIPAL INTEREST ESCROW AMOUNT/CD/DESCRIPTION 10-04-02 05-02 161 ESCROW ADVANCE 30.69 0.00 0.00 30.69 10-04-02 04-03 310 MORTGAGE INSURANCE DISBURSEMENT 30.69- 0.00 0.00 30.69- PAYEE = RBP 466.86- 09-16-02 05-02 152 LATE CHARGE ASSESSMENT 0.00 0.00 0.00 0.00 28.30-1 LATE CHARGE 09-11-02 05-02 186 2,926.59 0.00 2,926.59 0.00 6 09-11-02 05-02 186 75,716.58 75,716.58 0.00 0.00 6 75,716.58 ---* PF2 FOR ADDL MESSAGES *--------------------------------------------------- LOAN IS ACTIVE FORECLOSURE LOAN IS IN FORECLOSURE, F/C STOP = 3 FULL SETTLEMENT 09/11/02 LOAN PAST DUE 009 MONTHS 037 DAYS PAST PROJECTED LEGAL DATE PROCESSING NOTES ARE PRESENT SER1 5224903608 CUSTOMER SERVICE INV A91/002 01/06/03 11:18:14 ROBERT E WATSONIII 158-82-5392 1C TYPE F.H.A. MAN F ANGIE M WATSON 177-60-4931 IR 7.75000 BR 00 717-486-3160 145 FAITH CIRCLE CARLISLE PA 17013-8869 B 301-863-6526 _ < RCVD FIRST AMERICAN INV/01516310 THE INVOICE IS >: 12/23/02 ---- "HIST ---------------------- * LOAN HISTORY *--------------------------(MORE) PROC-DT DUE-DT TRAN TRAM-DESCRIPTION TRAN-EFFECTIVE-DATE TRAM-AMT PRINCIPAL INTEREST ESCROW AMOUNT/CD/DESCRIPTION 09-06-02 04-03 310 MORTGAGE INSURANCE DISBURSEMENT 30.69- 0.00 0.00 30.69- PAYEE = RBP 436.17- 09-06-02 05-02 30.69 09-03-02 00-00 1,500.00 09-03-02 00-00 250.00 08-16-02 05-02 0.00 161 ESCROW ADVANCE 0.00 0.00 30.69 632 STATUTORY EXPENSES 0.00 0.00 0.00 632 STATUTORY EXPENSES 0.00 0.00 0.00 152 LATE CHARGE ASSESSMENT 0.00 0.00 0.00 1,500.00 MTGR REC CORP ADV BA 250.00 MTGR REC CORP ADV BA 28.30-1 LATE CHARGE ---* PF2 FOR ADDL MESSAGES *--------------------------------------------------- LOAN IS ACTIVE FORECLOSURE LOAN IS IN FORECLOSURE, F/C STOP = 3 FULL SETTLEMENT 09/11/02 LOAN PAST DUE 009 MONTHS 037 DAYS PAST PROJECTED LEGAL DATE PROCESSING NOTES ARE PRESENT SER1 5224903608 CUSTOMER SERVICE INV A91/002 01/06/03 11:18:14 ROBERT E WATSONIII 158-82-5392 1C TYPE F.H.A. MAN F ANGIE M WATSON 177-60-4931 IR 7.75000 BR 00 717-486-3160 145 FAITH CIRCLE CARLISLE PA 17013-8869 B 301-863-6526 _ < RCVD FIRST AMERICAN INV/01516310 THE INVOICE IS >: 12/23/02 ---- "HIST---------------------- * LOAN HISTORY *--------------------------(MORE) PROC-DT DUE-DT TRAN TRAM-DESCRIPTION TRAM-EFFECTIVE-DATE TRAN-AMT PRINCIPAL INTEREST ESCROW AMOUNT/CD/DESCRIPTION 08-06-02 04-03 310 MORTGAGE INSURANCE DISBURSEMENT 30.69- 0.00 0.00 30.69- PAYEE = RBP 405.48- 08-06-02 05-02 161 ESCROW ADVANCE 30.69 0.00 0.00 30.69 07-30-02 08-02 314 LIEN DISBURSEMENT 873.98- 0.00 0.00 873.98- PAYEE = 370410604 374.79- 07-30-02 05-02 161 ESCROW ADVANCE 374.79 0.00 0.00 374.79 07-16-02 05-02 152 LATE CHARGE ASSESSMENT 0.00 0.00 0.00 0.00 28.30-1 LATE CHARGE ---* PF2 FOR ADDL MESSAGES *--------------------------------------------------- LOAN IS ACTIVE FORECLOSURE LOAN IS IN FORECLOSURE, F/C STOP = 3 FULL SETTLEMENT 09/11/02 LOAN PAST DUE 009 MONTHS 037 DAYS PAST PROJECTED LEGAL DATE PROCESSING NOTES ARE PRESENT SERI 5224903608 CUSTOMER SERVICE INV A91/002 01/06/03 11:18:14 ROBERT E WATSONIII 158-82-5392 1C TYPE F.H.A. MAN F ANGIE M WATSON 177-60-4931 IR 7.75000 BR 00 717-486-3160 145 FAITH CIRCLE CARLISLE PA 17013-8869 B 301-863-6526 _ < RCVD FIRST AMERICAN INV/01516310 THE INVOICE IS >: 12/23/02 ---- "HIST ---------------------- * LOAN HISTORY *--------------------------(MORE) PROC-DT DUE-DT TRAM TRAN-DESCRIPTION TRAN-EFFECTIVE-DATE TRAM-AMT PRINCIPAL INTEREST ESCROW AMOUNT/CD/DESCRIPTION 07-05-02 04-03 310 MORTGAGE INSURANCE DISBURSEMENT 30.69- 0.00 0.00 30.69- PAYEE = RBP 499.19 06-17-02 05-02 152 LATE CHARGE ASSESSMENT 0.00 0.00 0.00 0.00 28.16-1 LATE CHARGE 06-07-02 04-03 310 MORTGAGE INSURANCE DISBURSEMENT 30.69- 0.00 0.00 30.69- PAYEE = RBP 529.88 05-16-02 05-02 152 LATE CHARGE ASSESSMENT 0.00 0.00 0.00 0.00 28.16-1 LATE CHARGE 05-08-02 04-03 310 MORTGAGE INSURANCE DISBURSEMENT 30.69- 0.00 0.00 30.69- PAYEE = RBP ---* PF2 FOR ADDL MESSAGES *--------------------------------------------------- LOAN IS ACTIVE FORECLOSURE LOAN IS IN FORECLOSURE, F/C STOP = 3 FULL SETTLEMENT 09/11/02 LOAN PAST DUE 009 MONTHS 037 DAYS PAST PROJECTED LEGAL DATE PROCESSING NOTES ARE PRESENT SERI 5224903608 CUSTOMER SERVICE INV A91/002 01/06/03 11:18:14 ROBERT E WATSONIII 158-82-5392 1C TYPE F.H.A. MAN F ANGIE M WATSON 177-60-4931 IR 7.75000 BR 00 717-486-3160 145 FAITH CIRCLE CARLISLE PA 17013-8869 B 301-863-6526 _ < RCVD FIRST AMERICAN INV/01516310 THE INVOICE IS >: 12/23/02 ---- HIST---------------------- * LOAN HISTORY *--------------------------(MORE) PROC-DT DUE-DT TRAN TRAN-DESCRIPTION TRAN-EFFECTIVE-DATE TRAN-AMT PRINCIPAL INTEREST ESCROW AMOUNT/CD/DESCRIPTION 560.57 04-24-02 04-02 172 PAYMENT 704.00 75.47 489.49 138.92 0.12 1 LATE CHARGE 75,716.58 591.26 04-16-02 04-02 152 LATE CHARGE ASSESSMENT 0.00 0.00 0.00 0.00 28.16-1 LATE CHARGE 04-05-02 04-02 310 MORTGAGE INSURANCE DISBURSEMENT 31.06- 0.00 0.00 31.06- PAYEE = RBP 452.34 04-02-02 04-02 313 TAX DISBURSEMENT 281.89- 0.00 0.00 281.89- PAYEE = 370410203 483.40 ---* PF2 FOR ADDL MESSAGES *--------------------------------------------------- LOAN IS ACTIVE FORECLOSURE LOAN IS IN FORECLOSURE, F/C STOP = 3 FULL SETTLEMENT 09/11/02 LOAN PAST DUE 009 MONTHS 037 DAYS PAST PROJECTED LEGAL DATE PROCESSING NOTES ARE PRESENT SER1 5224903608 CUSTOMER SERVICE INV A91/002 01/06/03 11:18:14 ROBERT E WATSONIII 158-82-5392 1C TYPE F.H.A. MAN F ANGIE M WATSON 177-60-4931 IR 7.75000 BR 00 717-486-3160 145 FAITH CIRCLE CARLISLE PA 17013-8869 B 301-863-6526 < RCVD FIRST AMERICAN INV/01516310 THE INVOICE IS >: 12/23/02 ---- `HIST ---------------------- * LOAN HISTORY *--------------------------(MORE) PROC-DT DUE-DT TRAN TRAN-DESCRIPTION TRAN-EFFECTIVE-DATE TRAN-AMT PRINCIPAL INTEREST ESCROW AMOUNT/CD/DESCRIPTION 03-21-02 03-02 172 PAYMENT 03-20-02 704.00 74.99 489.97 138.92 0.12 1 LATE CHARGE 75,792.05 765.29 03-18-02 03-02 152 LATE CHARGE ASSESSMENT 0.00 0.00 0.00 0.00 28.16-1 LATE CHARGE 03-06-02 04-02 310 MORTGAGE INSURANCE DISBURSEMENT 31.06- 0.00 0.00 31.06- PAYEE = RBP 626.37 03-01-02 03-02 351 HAZARD INSURANCE DISBURSEMENT 219.00- 0.00 0.00 219.00- PAYEE = 70179 657.43 ---* PF2 FOR ADDL MESSAGES *--------------------------------------------------- LOAN IS ACTIVE FORECLOSURE LOAN IS IN FORECLOSURE, F/C STOP = 3 FULL SETTLEMENT 09/11/02 LOAN PAST DUE 009 MONTHS 037 DAYS PAST PROJECTED LEGAL DATE PROCESSING NOTES ARE PRESENT SER1 5224903608 CUSTOMER SERVICE INV A91/002 01/06/03 11:18:14 ROBERT E WATSONIII 158-82-5392` 1C TYPE F.H.A. MAN F ANGIE M WATSON 177-60-4931 IR 7.75000 BR 00 717-486-3160 145 FAITH CIRCLE CARLISLE PA 17013-8869 B 301-863-6526 < RCVD FIRST AMERICAN INV/01516310 THE INVOICE IS >: 12/23/02 ---- HIST---------------------- * LOAN HISTORY *--------------------------(MORE) PROC-DT DUE-DT TRAN TRAN-DESCRIPTION TRAN-EFFECTIVE-DATE TRAN-AMT PRINCIPAL INTEREST ESCROW AMOUNT/CD/DESCRIPTION 02-19-02 02-02 172 PAYMENT 732.04 74.50 490.46 138.92 28.16 1 LATE CHARGE 75,867.04 876.43 02-18-02 02-02 152 LATE CHARGE ASSESSMENT 0.00 0.00 0.00 0.00 28.16-1 LATE CHARGE 02-06-02 04-02 310 MORTGAGE INSURANCE DISBURSEMENT 31.06- 0.00 0.00 31.06- PAYEE = RBP 737.51 01-29-02 01-02 172 PAYMENT 733.86 74.03 490.93 138.92 29.98 1 LATE CHARGE 75,941.54 768.57 ---* PF2 FOR ADDL MESSAGES *--------------------------------------------------- LOAN IS ACTIVE FORECLOSURE LOAN IS IN FORECLOSURE, F/C STOP = 3 FULL SETTLEMENT 09/11/02 LOAN PAST DUE 009 MONTHS 037 DAYS PAST PROJECTED LEGAL DATE PROCESSING NOTES ARE PRESENT SER1 5224903608 CUSTOMER SERVICE INV A91/002 01/06/03 11:18:14 ROBERT E WATSONIII 158-82-5392 1C TYPE F.H.A. MAN F ANGIE M WATSON 177-60-4931 IR 7.75000 BR 00 717-486-3160 145 FAITH CIRCLE CARLISLE PA 17013-8869 B 301-863-6526 < RCVD FIRST AMERICAN INV/01516310 THE INVOICE IS >: 12/23/02 ---- "HIST ---------------------- * LOAN HISTORY *--------------------------(MORE) PROC-DT DUE-DT TRAN TRAN-DESCRIPTION TRAN-EFFECTIVE-DATE TRAN-AMT PRINCIPAL INTEREST ESCROW AMOUNT/CD/DESCRIPTION 01-16-02 01-02 152 LATE CHARGE ASSESSMENT 0.00 0.00 0.00 0.00 28.16-1 LATE CHARGE 01-08-02 04-02 310 MORTGAGE INSURANCE DISBURSEMENT 31.06- 0.00 0.00 31.06- PAYEE = RBP 629.65 12-31-01 01-02 160 INTEREST ON ESCROW DEPOSIT 13.23 0.00 0.00 13.23 660.71 12-26-01 12-01 172 PAYMENT 778.82 73.55 491.41 184.46 29.40 1 LATE CHARGE 76,015.57 647.48 ---* PF2 FOR ADDL MESSAGES *--------------------------------------------------- LOAN IS ACTIVE FORECLOSURE LOAN IS IN FORECLOSURE, F/C STOP = 3 FULL SETTLEMENT 09/11/02 LOAN PAST DUE 009 MONTHS 037 DAYS PAST PROJECTED LEGAL DATE PROCESSING NOTES ARE PRESENT SERI 5224903608 CUSTOMER SERVICE INV A91/002 01/06/03 11:18:15 ROBERT E WATSONIII 158-82-5392 1C TYPE F.H.A. MAN F ANGIE M WATSON 177-60-4931 IR 7.75000 BR 00 717-486-316( 145 FAITH CIRCLE CARLISLE PA 17013-8869 B 301-863-652E _ < RCVD FIRST AMERICAN INV/01516310 THE INVOICE IS >: 12/23/02 -----HIST---------------------- * LOAN HISTORY *--------------------------(MORE) PROC-DT DUE-DT TRAN TRAM-DESCRIPTION TRAN-EFFECTIVE-DATE TRAM-AMT PRINCIPAL INTEREST ESCROW AMOUNT/CD/DESCRIPTION 12-17-01 12-01 152 LATE CHARGE ASSESSMENT 0.00 0.00 0.00 0.00 29.98-1 LATE CHARGE 12-04-01 04-02 310 MORTGAGE INSURANCE DISBURSEMENT 31.06- 0.00 0.00 31.06- PAYEE = RBP 463.02 11-30-01 11-01 172 PAYMENT 750.00 73.08 491.88 184.46 0.58 1 LATE CHARGE 76,089.12 494.08 11-21-01 00-00 307 ESCROW REFUND 481.12- 0.00 0.00 481.12- 309.62 ---* PF2 FOR ADDL MESSAGES *------------------- -------------------------------- LOAN IS ACTIVE FORECLOSURE LOAN IS IN FORECLOSURE, F/C STOP = 3 FULL SETTLEMENT 09/11/02 LOAN PAST DUE 009 MONTHS 037 DAYS PAST PROJECTED LEGAL DATE PROCESSING NOTES ARE PRESENT SER1 5224903608 CUSTOMER SERVICE INV A91/002 01/06/03 11:18:14 ROBERT E WATSONIII 158-82-5392 1C TYPE F.H.A. MAN F ANGIE M WATSON 177-60-4931 IR 7.75000 BR 00 717-486-3160 145 FAITH CIRCLE CARLISLE PA 17013-8869 B 301-863-6526 < RCVD FIRST AMERICAN INV/01516310 THE INVOICE IS >: 12/23/02 ---- 'HIST---------------------- * LOAN HISTORY *--------------------------(MORE) PROC-DT DUE-DT TRAN TRAM-DESCRIPTION TRAN-EFFECTIVE-DATE TRAN-AMT PRINCIPAL INTEREST ESCROW AMOUNT/CD/DESCRIPTION 11-16-01 11-01 152 LATE CHARGE ASSESSMENT 0.00 0.00 0.00 0.00 29.98-1 LATE CHARGE 11-02-01 04-02 310 MORTGAGE INSURANCE DISBURSEMENT 31.06- 0.00 0.00 31.06- PAYEE = RBP 790.74 10-16-01 10-01 172 PAYMENT 749.42 72.61 492.35 184.46 76,162.20 821.80 10-04-01 04-02 310 MORTGAGE INSURANCE DISBURSEMENT 31.06- 0.00 0.00 31.06- PAYEE = RBP 637.34 ---* PF2 FOR ADDL MESSAGES *--------------------------------------------------- LOAN IS ACTIVE FORECLOSURE LOAN IS IN FORECLOSURE, F/C STOP = 3 FULL SETTLEMENT 09/11/02 LOAN PAST DUE 009 MONTHS 037 DAYS PAST PROJECTED LEGAL DATE PROCESSING NOTES ARE PRESENT SERI 5224903608 CUSTOMER SERVICE INV A91/002 01/06/03 11:18:14 ROBERT E WATSONIII 158-82-5392 1C TYPE F.H.A. MAN F ANGIE M WATSON 177-60-4931 IR 7.75000 BR 00 717-486-3160 145 FAITH CIRCLE CARLISLE PA 17013-8869 B 301-863-6526 < RCVD FIRST AMERICAN INV/01516310 THE INVOICE IS >: 12/23/02 ---- "HIST---------------------- * LOAN HISTORY *--------------------------(MORE) PROC-DT DUE-DT TRAN TRAN-DESCRIPTION TRAN-EFFECTIVE-DATE TRAM-AMT PRINCIPAL INTEREST ESCROW AMOUNT/CD/DESCRIPTION 09-19-01 09-01 172 PAYMENT 09-18-01 777.90 72.14 492.82 184.46 28.48 1 LATE CHARGE 76,234.81 668.40 09-13-01 08-01 314 LIEN DISBURSEMENT 824.90- 0.00 0.00 824.90- PAYEE = 370410604 483.94 09-05-01 04-02 310 MORTGAGE INSURANCE DISBURSEMENT 31.06- 0.00 0.00 31.06- PAYEE = RBP 1,308.84 08-21-01 08-01 172 PAYMENT 08-17-01 749.92 71.68 493.28 184.46 0.50 1 LATE CHARGE 76,306.95 1,339.90 ---* PF2 FOR ADDL MESSAGES *--------------------------------------------------- LOAN IS ACTIVE FORECLOSURE LOAN IS IN FORECLOSURE, F/C STOP = 3 FULL SETTLEMENT 09/11/02 LOAN PAST DUE 009 MONTHS 037 DAYS PAST PROJECTED LEGAL DATE PROCESSING NOTES ARE PRESENT SER1 5224903608 CUSTOMER SERVICE INV A91/002 01/06/03 11:18:14 ROBERT E WATSONIII 158-82-5392 1C TYPE F.H.A. MAN F ANGIE M WATSON 177-60-4931 IR 7.75000 BR 00 717-486-3160 145 FAITH CIRCLE CARLISLE PA 17013-8869 B 301-863-6526 _ < RCVD FIRST AMERICAN INV/01516310 THE INVOICE IS >: 12/23/02 ---- "HIST---------------------- * LOAN HISTORY *--------------------------(MORE) PROC-DT DUE-DT TRAN TRAN-DESCRIPTION TRAM-EFFECTIVE-DATE TRAN-AMT PRINCIPAL INTEREST ESCROW AMOUNT/CD/DESCRIPTION 07-30-01 08-01 172 PAYMENT 30.48 0.00 0.00 0.00 30.48 1 LATE CHARGE 07-30-01 07-01 172 PAYMENT 749.42 71.22 493.74 184.46 76,378.63 1,155.44 07-20-01 04-02 310 MORTGAGE INSURANCE DISBURSEMENT 31.06- 0.00 0.00 31.06- PAYEE = RBP 970.98 07-16-01 07-01 152 LATE CHARGE ASSESSMENT 0.00 0.00 0.00 0.00 29.98-1 LATE CHARGE 07-03-01 04-02 310 MORTGAGE INSURANCE DISBURSEMENT 31.06- 0.00 0.00 31.06- PAYEE = RBP ---* PF2 FOR ADDL MESSAGES *---------------------------------- --------------- LOAN IS ACTIVE FORECLOSURE LOAN IS IN FORECLOSURE, F/C STOP = 3 FULL SETTLEMENT 09/11/02 LOAN PAST DUE 009 MONTHS 037 DAYS PAST PROJECTED LEGAL DATE PROCESSING NOTES ARE PRESENT SERI 5224903608 CUSTOMER SERVICE INV A91/002 01/06/03 11:18:14 ROBERT E WATSONIII 158-82-5392 1C TYPE F.H.A. MAN F ANGIE M WATSON 177-60-4931 IR 7.75000 BR 00 717-486-3160 145 FAITH CIRCLE CARLISLE PA 17013-8869 B 301-863-6526 _ < RCVD FIRST AMERICAN INV/01516310 THE INVOICE IS >: 12/23/02 ---- "HIST---------------------- * LOAN HISTORY *--------------------------(MORE) PROC-DT DUE-DT TRAN TRAM-DESCRIPTION TRAM-EFFECTIVE-DATE TRAN-AMT PRINCIPAL INTEREST ESCROW AMOUNT/CD/DESCRIPTION 06-28-01 07-01 0.50 06-28-01 06-01 749.42 06-18-01 06-01 0.00 06-04-01 04-02 31.06- 172 PAYMENT 0.00 172 PAYMENT 70.76 4 76,449.85 152 LATE C 0.00 310 MORTGAGE 0.00 1,002.04 0.00 0.00 0.50 1 LATE CHARGE 94.20 184.46 1,033.10 HARGE ASSESSMENT 0.00 0.00 29.98-1 INSURANCE DISBURSEMENT 0.00 31.06- 848.64 LATE CHARGE PAYEE RBP ---* PF2 FOR ADDL MESSAGES *--------------------------------------------------- LOAN IS ACTIVE FORECLOSURE LOAN IS IN FORECLOSURE, F/C STOP = 3 FULL SETTLEMENT 09/11/02 LOAN PAST DUE 009 MONTHS 037 DAYS PAST PROJECTED LEGAL DATE PROCESSING NOTES ARE PRESENT SER1 5224903608 CUSTOMER SERVICE INV A91/002 01/06/03 11:18:14 ROBERT E WATSONIII 158-82-5392 1C TYPE F.H.A. MAN F ANGIE M WATSON 177-60-4931 IR 7.75000 BR 00 717-486-3160 145 FAITH CIRCLE CARLISLE PA 17013-8869 B 301-863-6526 < RCVD FIRST AMERICAN INV/01516310 THE INVOICE IS >: 12/23/02 ----"HIST---------------------- * LOAN HISTORY *--------------------------(MORE) PROC-DT DUE-DT TRAN TRAN-DESCRIPTION TRAN-EFFECTIVE-DATE TRAN-AMT PRINCIPAL INTEREST ESCROW AMOUNT/CD/DESCRIPTION 05-16-01 05-01 172 PAYMENT 749.92 70.31 494.65 184.46 0.50 MISCELLANEOUS 76,520.61 879.70 05-02-01 04-02 310 MORTGAGE INSURANCE DISBURSEMENT 31.06- 0.00 0.00 31.06- PAYEE = RBP 695.24 04-13-01 04-01 172 PAYMENT 749.92 69.86 495.10 184.46 0.50 MISCELLANEOUS 76,590.92 726.30 04-09-01 04-01 313 TAX DISBURSEMENT 260.40- 0.00 0.00 260.40- PAYEE = 370410569) 541.84 ---* PF2 FOR ADDL MESSAGES *--------------------------------------------------- LOAN IS ACTIVE FORECLOSURE LOAN IS IN FORECLOSURE, F/C STOP = 3 FULL SETTLEMENT 09/11/02 LOAN PAST DUE 009 MONTHS 037 DAYS PAST PROJECTED LEGAL DATE PROCESSING NOTES ARE PRESENT SER1 5224903608 CUSTOMER SERVICE INV A91/002 01/06/03 11:18:14 ROBERT E WATSONIII 158-82-5392 1C TYPE F.H.A. MAN F ANGIE M WATSON 177-60-4931 IR 7.75000 BR 00 717-486-3160 145 FAITH CIRCLE CARLISLE PA 17013-8869 B 301-863-6526 < RCVD FIRST AMERICAN INV/01516310 THE INVOICE IS >: 12/23/02 ---- "HIST---------------------- * LOAN HISTORY *--------------------------(MORE) PROC-DT DUE-DT TRAN TRAM-DESCRIPTION TRAM-EFFECTIVE-DATE TRAN-AMT PRINCIPAL INTEREST ESCROW AMOUNT/CD/DESCRIPTION 04-04-01 04-01 310 MORTGAGE INSURANCE DISBURSEMENT 31.40- 0.00 0.00 31.40- PAYEE = RBP 802.24 03-15-01 03-01 172 PAYMENT 749.92 69.41 495.55 184.46 0.50 MISCELLANEOUS 76,660.78 833.64 03-07-01 04-01 310 MORTGAGE INSURANCE DISBURSEMENT 31.40- 0.00 0.00 31.40- PAYEE = RBP 649.18 02-23-01 03-01 351 HAZARD INSURANCE DISBURSEMENT 209.00- 0.00 0.00 209.00- PAYEE = 70325 680.58 ---* PF2 FOR ADDL MESSAGES *--------------------------------------------------- LOAN IS ACTIVE FORECLOSURE LOAN IS IN FORECLOSURE, F/C STOP = 3 FULL SETTLEMENT 09/11/02 LOAN PAST DUE 009 MONTHS 037 DAYS PAST PROJECTED LEGAL DATE PROCESSING NOTES ARE PRESENT ROBERT E WATSONIII 158-82-5392 1C TYPE F.H.A. MAN F ANGIE M WATSON 177-60-4931 IR 7.75000 BR 00 717-486-316( 145 FAITH CIRCLE CARLISLE PA 17013-8869 B 301-863-652( _ < RCVD FIRST AMERICAN INV/01516310 THE INVOICE IS >: 12/23/02 ----- HIST---------------------- * LOAN HISTORY * -------------------------- (MORE) PROC-DT DUE-DT TRAN TRAM-DESCRIPTION TRAM-EFFECTIVE-DATE TRAN-AMT PRINCIPAL INTEREST ESCROW AMOUNT/CD/DESCRIPTION 02-12-01 02-01 172 PAYMENT 749.92 68.97 495.99 184.46 0.50 MISCELLANEOUS 76,730.19 889.58 02-07-01 04-01 310 MORTGAGE INSURANCE DISBURSEMENT 31.40- 0.00 0.00 31.40- PAYEE = RBP 705.12 01-31-01 02-01 175 PRINCIPAL PAYMENT 1.54 1.54 0.00 0.00 76,799.16 01-31-01 02-01 172 PAYMENT 59.54 0.00 0.00 0-0() so Sd , T_Ama rlLlmm +c ---* PF2 FOR ADDL MESSAGES *-------------------- ------------------------------- LOAN IS ACTIVE FORECLOSURE LOAN IS IN FORECLOSURE, F/C STOP = 3 FULL SETTLEMENT 09/11/02 LOAN PAST DUE 009 MONTHS 037 DAYS PAST PROJECTED LEGAL DATE PROCESSING NOTES ARE PRESENT ROBERT E WATSONIII 158-82-5392 1C TYPE F.H.A. MAN F ANGIE M WATSON 177-60-4931 IR 7.75000 BR 00 717-486-3160 145 FAITH CIRCLE CARLISLE PA 17013-8869 B 301-863-6526 < RCVD FIRST AMERICAN INV/01516310 THE INVOICE IS >: 12/23/02 ----- HIST------------------ * END OF LOAN HISTORY * ---------------------(MORE) PROC-DT DUE-DT TRAN TRAN-DESCRIPTION TRAN-EFFECTIVE-DATE TRAN-AMT PRINCIPAL INTEREST ESCROW AMOUNT/CD/DESCRIPTION 01-31-01 01-01 172 PAYMENT 749.92 68.51 496.45 184.46 0.50 MISCELLANEOUS 76,800.70 736.52 01-31-01 02-01 160 INTEREST ON ESCROW DEPOSIT 1.23 0.00 0.00 1.23 552.06 01-16-01 01-01 152 LATE CHARGE ASSESSMENT 0.00 0.00 0.00 0.00 29.98-1 LATE CHARGE 01-03-01 04-01 310 MORTGAGE INSURANCE DISBURSEMENT 31.40- 0.00 0.00 31.40- PAYEE = RBP 550.83 ---* PF2 FOR ADDL MESSAGES *--------------------------------------------------- LOAN IS ACTIVE FORECLOSURE LOAN IS IN FORECLOSURE, F/C STOP = 3 FULL SETTLEMENT 09/11/02 LOAN PAST DUE 009 MONTHS 037 DAYS PAST PROJECTED LEGAL DATE PROCESSING NOTES ARE PRESENT ROBERT E WATSONIII 158-82-5392 1C TYPE F.H.A. MAN F ANGIE M WATSON 177-60-4931 IR 7.75000 BR 00 717-486-3160 145 FAITH CIRCLE CARLISLE PA 17013-8869 B 301-863-6526 _ < RCVD FIRST AMERICAN INV/01516310 THE INVOICE IS >: 12/23/02 ---- HIST------------------ * END OF LOAN HISTORY *----------------------(MORE) PROC-DT DUE-DT TRAM TRAN-DESCRIPTION TRAN-EFFECTIVE-DATE TRAN-AMT PRINCIPAL INTEREST ESCROW AMOUNT/CD/DESCRIPTION 01-31-01 01-01 172 PAYMENT 749.92 68.51 496.45 184.46 0.50 MISCELLANEOUS 76,800.70 736.52 01-31-01 02-01 160 INTEREST ON ESCROW DEPOSIT 1.23 0.00 0.00 1.23 552.06 01-16-01 01-01 152 LATE CHARGE ASSESSMENT 0.00 0.00 0.00 0.00 29.98-1 LATE CHARGE 01-03-01 04-01 310 MORTGAGE INSURANCE DISBURSEMENT 31.40- 0.00 0.00 31.40- PAYEE = RBP 550.83 ---* PF2 FOR ADDL MESSAGES *--------------------------------------------------- LOAN IS ACTIVE FORECLOSURE LOAN IS IN FORECLOSURE, F/C STOP = 3 FULL SETTLEMENT 09/11/02 LOAN PAST DUE 009 MONTHS 037 DAYS PAST PROJECTED LEGAL DATE PROCESSING NOTES ARE PRESENT Washington Mutual 2210 Enterprise Drive 5224903608 P.O. Boa 100500 Florence, SC 29501-0500 July 11, 2002 # BWNCLNN# # 0952249903960897# 00+1751eaww Lm Robert E. Watsonui Angie M. Watson 145 Faith Circle Carlisle PA 17013 RE: 5224903608 FHA 145 Faith Circle Carlisle PA 17013-8869 Dear Borrower: The records of Washington Mutual Home Loans, Inc. indicate that as of the date of this letter, you have failed to make the required monthly payments under the terms of your Note ( Note") and related Mortgage or Deed of Trust, whichever is applicable ("Security Instrument") since 05/01!2002. The total amount presently due and owing ("Total Amount Due") consists of the following Principal & Interest Pe ent:$ s 1694.88 E crow: 416.76 Accumulated Unpaid Late Charges: 140.56 Outstanding Fees Total: 0.00 Credits: 0.00 Total Amount Due:$ 2255.91 The terms of the Note and Security Instrument require you to pay each monthly payment and any related late charge and other fees when due. This correspondence will serve o notify you that you are in default under the terms of your Note and Security Instrument because of your failure to pay the above mentioned Monthly Payments, related late charges and fees when due. cure letter Home Loans, Inc. the total amount due plus any additional monthly payments and leis-charges-fading due within this forty day period. Failure to cure such default within the 40-day period will result in Washington Mutual declazing the entire eutuandinS principal balan cy accrued interest and any other fees and charges due under the terms of the Note and Severity be to be Immediately due ("AeceI anon"). If this amount is not immediately paid at such time, Washington Mutual may ezttmse its remedies available under the terms of the Note and Security instrument and applicable law, including the commencement of foreclosure proceedings which may result in the sale of your property. After acceleration, you will have the right to assert any grounds you may have to prove the non-eaistonce of a default. You may also reinstate your loan. In addition, you will have the right in any related foreclosure proceedings to assert any defense to acceleration, the foreclosure litigation and, if applicable, the eventual sale of your property pursuant to a court order or trustee power of sale. Please contact our office immediately to discuss your account status. Our toll free number is 1-800-254-3677. Sincerely, Collection Department Applicable law requires us to inform you that, under these circumstances, we are acting as a debt collect or, we are attempting to collect a debt, and any information will be used for that purpose. DEMAND LTR fT£1 (41?'4 ZX008ZX969T) TTq'GZi,880U13 CERTIFICATE OF SERVICE I, Barbara A. Shadel, an employee of the law firm of Purcell, Krug & Haller, do hereby certify that I served a true and correct copy of Summary Judgment Affidavit upon the following by depositing same in the United States Mail, First Class Postage, Postage Prepaid, addressed as follows: Karl E. Rominger, Esquire 155 South Hanover Street Carlisle, PA 17013 Attorney for Plaintiff, Angie M. Watson Robert E. Watson, III 145 Faith Circle Carlisle, PA 17013 Pro Se Defendant Barbara A. Shadel Dated: lh-71d as r, - -. WASHINGTON MUTUAL BANK, FA f/k/a PNC MORTGAGE CORP. OF AMERICA, Plaintiff vs. ANGIE M. WATSON and ROBERT E. WATSON, III, Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND CO., PENNSYLVANIA NO. 02-4172 CIVIL ACTION - LAW IN MORTGAGE FORECLOSURE AND NOW, comes Plaintiff, Washington Mutual Bank, FA f/kFa PNC Mortgage Corp. of America, by its attorneys, Purcell, Krug & Haller, and files the following Motion for incorporation of the attached Stipulation: 1. Movant/Plaintiff, Washington Mutual Bank, FA f/k/a PNC Mortgage Corp. of America, filed a Complaint in Mortgage Foreclosure on September 3, 2002. 2. The Defendant, Robert E. Watson, III has not filed an ,Answer to the Plaintiffs Complaint. 3. The Defendant, Angie M. Watson filed an Answer to the Plaintiffs Complaint on October 22, 2002. 4. The Plaintiffs counsel and the Defendant, Angie M. Watson, have signed a Stipulation, agreeing to the entry of an in rem judgment in favor of the Plaintiff, Washington Mutual Bank, FA f/k/a PNC Mortgage Corp. of America, and against the Defendant, Angie M. Watson, in the sum of $84,102.04. together with interest of $16.07 diem from February 1 for taxes and insurance. The original signed Stipulation is attached hereto. WHEREFORE, Plaintiff respectfully requests this Honorable Court to issue an Order incorporating the terms of the attached Stipulation. Respectfully submitted, Jill . Wineka, Esquire A mey ID # 58802 PURCELL, KRUG & HALLER 1719 North Front Street Harrisburg, PA 17102 Dated: 0 / I /o3 (717) 234-4178 Attorneys for Plaintiff 2003, plus any additional costs and escrow advances WASHINGTON MUTUAL BANK, FA f/k/a PNC MORTGAGE CORP. OF AMERICA, Plaintiff vs. ANGIE M. WATSON and ROBERT E. WATSON, III, Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND CO., PENNSYLVANIA NO. 02-4172 CIVIL ACTION - LAW IN MORTGAGE FORECLOSURE STIP CATION It is hereby stipulated and agreed by and between Jill M. Wineka, Esquire, Attorney for Plaintiff, Washington Mutual Bank, FA f/k/a PNC Mortgage Corp. of America, and Defendant, Angie M. Watson, that an in rem judgment in mortgage foreclosure is to be entered in favor of the Plaintiff, Washington Mutual Bank, FA f/k/a PNC Mortgage Corp. of America and against the Defendant, Angie M. Watson in the amount of $84,102.04, together with interest at the rate of $16.07 per diem from February 1, 2003, together with any additional advances for costs and escrow advances, taxes and insurance. Jill . Wineka, Esquire, Attrney for Plaintiff, Washington Mutual Bank, g1e M Wats n, defendant FA f/k/a PNC Mortgage Corp. of America Dated: K-1 0o 3 -? 3 Dated: CERTIFI -ATF OF SERVICE: Barbara A. Shadel, an employee of Purcell, Krug & Haller, do hereby certify that I served a true and correct copy of the Plaintiffs Motion upon the following by depositing same in the United States Mail, First Class Postage, Postage Prepaid, addressed as follows: Karl E. Rominger, Esquire Robert E. Watson, III 155 South Hanover Street 145 Faith Circle Carlisle, PA 17013 Carlisle, PA 17013 Attorney for Defendant, Pro Se Defendant Angie M. Watson Robert L. O'Brien, Esquire 17 West South Street Carlisle, PA 17013 Bankruptcy Attorney for Defendant, Angie M. Watson -LA-6, V4 j- Q Barbara A. Shadel Dated: 7 I 0103 (fd\midland\pidano\motion & sfip) ?-, , . , ?_ ;_ T;=? G7 v:. ': e, r'i! '; Gtr ... ;.: c..--. .. :.. ?.? WASHINGTON MUTUAL BANK, FAf/k/a PNC MORTGAGE CORP. OF AMERICA, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND CO., PENNSYLVANIA NO. 02-4172 vs. ANGIE M. WATSON and ROBERT E. WATSON, III, Defendants CIVIL ACTION - LAW IN MORTGAGE FORECLOSURE MOTION AND NOW, comes Plaintiff, Washington Mutual Bank, FA f/k/a PNC Mortgage Corp. of America, by its attorneys, Purcell, Krug & Haller, and files the following Motion for incorporation of the attached Stipulation: 1. Movant/Plaintiff, Washington Mutual Bank, FA f/k/a PNC Mortgage Corp. of America, filed a Complaint in Mortgage Foreclosure on September 3, 2002. 2. The Defendant, Robert E. Watson, III has not filed an Answer to the Plaintiffs Complaint. 3. The Defendant, Angie M. Watson filed an Answer to the Plaintiffs Complaint on October 22, 2002. 4. The Plaintiffs counsel and the Defendant, Angie M. Watson, have signed a Stipulation, agreeing to the entry of an in rem judgment in favor of the Plaintiff, Washington Mutual Bank, FA f/k/a PNC Mortgage Corp. of America, and against the Defendant, Angie M. Watson, in the sum of $84,102.04, together with interest of $16.07 diem from February 1, 2003, plus any additional costs and escrow advances for taxes and insurance. The original signed Stipulation is attached hereto. WHEREFORE, Plaintiff respectfully requests this Honorable Court to issue an Order incorporating the terms of the attached Stipulation. Dated: F111 /0-3 Respectfully submitted, Ifl YV c Jill . Wineka, Esquire A rney ID # 58802 PURCELL, KRUG & HALLER 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 Attorneys for Plaintiff WASHINGTON MUTUAL BANK, FA f/k/a PNC MORTGAGE CORP. OF AMERICA, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND CO., PENNSYLVANIA NO. 02-4172 vs. ANGIE M. WATSON and ROBERT E. WATSON, III, Defendants CIVIL ACTION - LAW IN MORTGAGE FORECLOSURE STIPULATION it is hereby stipulated and agreed by and between Jill M. Wineka, Esquire, Attorney for Plaintiff, Washington Mutual Bank, FA f/k/a PNC Mortgage Corp. of America, and Defendant, Angie M. Watson, that an in rem judgment in mortgage foreclosure is to be entered in favor of the Plaintiff, Washington Mutual Bank, FA f/k/a PNC Mortgage Corp. of America and against the Defendant, Angie M. Watson in the amount of $84,102.04, together with interest at the rate of $16.07 per diem from February 1, 2003, together with any additional advances for costs and escrow advances, taxes and insurance. JilYrney ekaEsqu ire, gie M. Wats4, Defendant Atr Plaintiff, Washington Mutual Bank, FA f/k/a PNC Mortgage Corp. of America Dated: p'r /0 ':? Dated: J _ `t' -,9,4 CERTIFICATE OF SERVICE I, Barbara A. Shadel, an employee of Purcell, Krug & Haller, do hereby certify that I served a true and correct copy of the Plaintiff's Motion upon the following by depositing same in the United States Mail, First Class Postage, Postage Prepaid, addressed as follows: Karl E. Rominger, Esquire 155 South Hanover Street Carlisle, PA 17013 Attorney for Defendant, Angie M. Watson Robert L. O'Brien, Esquire 17 West South Street Carlisle, PA 17013 Bankruptcy Attorney for Defendant, Angie M. Watson Dated: 71/1/03 Robert E. Watson, III 145 Faith Circle Carlisle, PA 17013 Pro Se Defendant Barbara A. GShadel (fcl\midland\pidano\motion & slip) AUG 1 3 2003 r WASHINGTON MUTUAL BANK, FA f/k/a PNC MORTGAGE CORP. OF AMERICA, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND CO., PENNSYLVANIA NO. 02-4172 vs. ANGIE M. WATSON and ROBERT E. WATSON, III, Defendants AND NOW, this // ` day of CIVIL ACTION - LAW IN MORTGAGE FORECLOSURE ORDER /17"? , 2003, IT IS HEREBY ORDERED that the Prothonotary is directed to enter an in rem judgment in mortgage foreclosure in favor of the Plaintiff, Washington Mutual Bank, FA f/k/a PNC Mortgage Corp. of America and against the Defendant, Angie M. Watson, in the amount of $84,102.04, together with interest at the rate of $16.07 per diem from February 1, 2003, together with any additional costs and escrow advances for taxes and insurance. BY THE COURT: Distribution: ,Jiff M Wineka, Esq., 1719 North Front St., Harrisburg, PA 17102 j"rl E. Rominger, Esq., 155 South Hanover St., Carlisle, PA 17013 ,/Robert L. O'Brien, Esq., 17 West South St., Carlisle, PA 17013 / -,Robert E. Watson, III, 145 Faith Circle, Carlisle, PA 17013 V J. 4 na ` 1?aab? ??d WASHINGTON MUTUAL BANK, FA F/K/A PNC MORTGAGE CORP. OF AMERICA, PLAINTIFF vs. ANGIE M. WATSON AND ROBERT E, WATSON III, DEFENDANT(S) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. 02-4172 MORTGAGE FORECLOSURE PRAECIPE TO THE PROTHONOTARY OF THE WITHIN COUNTY: Please enter JUDGMENT in rem in favor of the Plaintiff and against Defendant(s) ROBERT E. WATSON III for failure to plead to the above action within twenty (20) days from date of service of the Complaint, and assess Plaintiffs damages as follows: Unpaid Principal Balance $75,716.58 Interest $2,458.71 Per diem of $16.07 From 04/01/2002 To 09/01/2002 Accumulated Late Charges $197.16 Late Charges $112.64 ($28.16 per month to 09/01/2002) Escrow Deficit $405.48 5% Attorney's Commission $3,785.83 TOTAL $82,686.40 "Together with additional interest at the per diem rate indicated above from the date herein, based on the contract rate, and other charges and costs to the date of Sheriffs Sale. PURCELL, KRUG & H R By Leo al er PA I.D. # 15700 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 WASHINGTON MUTUAL BANK, FA F/K/A PNC MORTGAGE CORP. OF AMERICA, PLAINTIFF Vs. ANGIE M. WATSON AND ROBERT E. WATSON III, DEFENDANT(S) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. 02-4172 IN MORTGAGE FORECLOSURE CERTIFICATE OF SERVICE PURSUANT TO PA. R.C.P. 237.1 I hereby certify that on October 14, 2002 I served the Ten Day Notice required by Pa. R.C.P. on the Defendant(s) in this matter by regular first class mail, postage prepaid, as indicated on the attached Notice. By Leon P. Haller PA I.D. # 15700 Attorney for Plaintiff Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 WASHINGTON MUTUAL BANK, FA, F/K/A PNC MORTGAGE CORP. OF AMERICA Plaintiff VS. ANGIE M. WATSON AND ROBERT E. WATSON III Defendants DATE OF THIS NOTICE: October 14, 2002 TO: ANGIE M. WATSON 7 PINEY COURT GARDNERS PA 17324 ROBERT E. WATSON III 145 FAITH CIRCLE CARLISLE, PA 17013 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-4172 CIVIL ACTION LAW IN MORTGAGE FORECLOSURE THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP: CUMBERLAND COUNTY LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 PURCELL, KRUG & H By P omey for Plaint f I.D. # 1 0 1719 N. Front St., Harrisburg, PA 17102 (717) 234-4178 -4U r_ ;. WASHINGTON MUTUAL BANK, FA F/K/A PNC MORTGAGE CORP. OF AMERICA, PLAINTIFF Vs. ANGIE M. WATSON AND ROBERT E. WATSON 111, DEFENDANT(S) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. 02-4172 IN MORTGAGE FORECLOSURE NON-MILITARY AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA SS COUNTY OF DAUPHIN Personally appeared before me, a Notary Public in and for said Commonwealth and County, LEON P. HALLER, ESQUIRE who being duly sworn according to law deposes and states that the Defendant (s) above named are not in the Military or Naval Service nor are they engaged in any way which would bring them within the Soldiers and Sailors Relief Act of 1940, as amended. Sworn to and subscribed before me this ??ay of 4??bPn 20_1::?3 Notary Public P. HALLER, ESQUI COWM WEALTH OF PENNSYLVANIA Ndarial Seel Trad M. Com, Mary PW ft III Clly Of Hrdedep Dw" O=* *Comidselu EVkwAug.21,2007 Member, PennsylvaMa Assodaeon Of Note rNa c? ? - c . . -? ,??.?: ?,: -, -; ` ?,-.? _,,. , . ? -, .? - , ' _? ?? ?? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION - LAW AT NO. 02-4172 WASHINGTON MUTUAL BANK, FA F/K/A PNC TOTAL AMOUNT OF MORTGAGE CORP. OF AMERICA, JUDGMENT PLAINT IFF VS. ANGIE M. WATSON AND ROBERT E. WATSON III, DEFENDANT(S) Interest Per diem of $16.07 to sale date Accumulated Late Charges Late Charges $28.16 per month to sale date Escrow Deficit $82,686.40 u $8,790.29 $197.16 $506.88 $1,500.00 5% Attorney's 3,785.83 Commission TOTAL WRIT $93,483.57 *Plus additional interest, late charges and other costs to date of sherifrs sale. SALE DATE: WEDNESDAY, MARCH 03, 2004 (PROTHONOTARY'S USE) P1tf. Paid Deft. Paid Due Proth/Clerk Other Costs PRAECIPE FOR WRIT OF EXECUTION - MORTGAGE FORECLOSURE TO THE PROTHONOTARY/CLERK OF SAID COURT: Issue Writ of Execution in the above captioned case. Date: September 30, 2003 Attorney for Plaintiff 1719 North Front Street eon P.. Haller Harrisburg, PA 17102 PA I.D. #15700 (717) 234-4178 WRIT OF EXECUTION - MORTGAGE FORECLOSURE COMMONWEALTH OF PENNSYLVANIA SS COUNTY OF CUMBERLAND TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the judgment, interest and costs in the above captioned case, you are directed to levy upon and sell the property described in the attached description known as 145 FAITH CIRCLE CARLISLE, PENNSYLVANIA 17013 Date: PROTHONOTARY/CLERK CIVIL DIVISION BY DEPUTY f r w _ h 0 C e O C ALL that certain nacl or parcel of land, with the buildings and improvements tbereon erected, SITUATE in the Township of North Middleton, County of Cumberland. Cnmmnonwealth of Pennsylvania and described in accordance with a Plan of property made by Larry V. Neidlinger, dated February 28, 1980, as follows, to wit: BEGINNING at an iron pin on the Westerly side of Faith Circle (60 feet wide), at a corncrof Lol No. 156; thence extending fronn said point of beginning and along Lot No. 156; North 89 degrees 34 minutes 18 seconds `Vest, the distance of 357.90 feet to a point, in line of lands of Kingsbrook Section 11; thence extending along the last mentioned lands, the two (2) following courses and distances, (1) North 25 degrees 25 minutes 35 seconds West, the distance of 15.77 feet to a point, and (2) North 43 degrees 30 minutes 42 seconds East, the distance of 49.02 feet to a point, at a corner of Lot No. 108; thence extending along Lot No. 108, South 89 degrees 34 minutes 18 seconds Last, the distance of 331.29 feet to an iron pin on tine Westerly side of Faith Circle; thence extending along the said side of Faith Circle, South 00 degrees 25 minutes 42 seconds East, the distance of 50.00 feet to the first mentioned point and place of BEGINNING. BEING shown as Lot Nos. 109 and 156-B on the plan or Kingsbrook, as recorded in plan Books: 27 al page 3 and 36 at Page 19. UNDER AND SUBJECT, NEVERTI IELESS, to all rights of way, easements, restrictions and/or conditions of record. HAVING THEREON ERECTED A DWELLING KNOWN AS 145 FAITH CIRCLE, CARLISLE, PENNSYLVANIA 17013 BEING THE SAME PREMISES WHICH Ernest A. Hoffstetter and Muriel Hoffstetter, by Deed dated 3/27/98 and recorded 3/30/98 in Cumberland County Deed Book 174, Page 347, granted and conveyed unto Robert E. Watson, III and Angie M. Watson. TO BE SOLD AS THE PROPERTY OF ANGIE M. WATSON AND ROBERT E. WATSON III ON JUDGMENT NO. 02-4172 ASSESSMENT NO. 29-14-08868-078 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 02-4172 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due WASHINGTON MUTUAL BANK, FA F/K/A PNC MORTGAGE CORP. OF AMERICA, Plaintiff (s) From ANGIE M. WATSON AND ROBERT E. WATSON III (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $82,686.40 L.L. $.50 Interest PER DIEM OF $16.07 TO SALE DATE - $8,790.29 Arty's Comm5%$3,785.83 Due Prothy $1.00 Any Paid $137.59 Other Costs ACCUMULATED LATE CHARGES $197.16 - LATE CHARGES $28.16 PER MONTH TO SALE DATE - $506.88 - ESCROW DEFICIT $1,500.00 Plaintiff Paid Date: OCTOBER 2, 2003 CURTIS R. LONG (S l) Prothono[a/ ea Deputy REQUESTING PARTY: Name LEON P. HALLER, ESQUIRE Address: 1719 NORTH FRONT STREET HARRISBURG, PA 17102 Attorney for: PLAINTIFF Telephone: 717-234-4178 Supreme Court ID No. 15700 WASHINGTON MUTUAL BANK, FA F/K/A PNC MORTGAGE CORP. OF AMERICA, PLAINTIFF vs. ANGIE M. WATSON AND ROBERT E. WATSON III, DEFENDANT(S) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. 02-4172 IN MORTGAGE FORECLOSURE AFFIDAVIT PURSUANT TO RULE 3129.1 The Plaintiff in the above action, by its attorneys, Purcell, Krug & Haller, sets forth as of the date the praecipe for the writ of execution was filed, the following information concerning the real property located at 145 FAITH CIRCLE CARLISLE, PENNSYLVANIA 17013: Name and address of the Owner(s) or Reputed Owner(s): ANGIE M. WATSON AWA ANGIE MAE WATSON 13 PARK STREET MOUNT HOLLY SPRINGS, PA 17065-1433 ROBERT E. WATSON III A/K/A ROBERT ELLSWORTH W'ATSON, III 5042 FRESH POND NECK ROAD RIDGE, MD 20680-3337 2. Name and address of Defendant(s) in the Judgment, if different from that listed. in (1) above: SAME 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: UNKNOWN 4. Name and address of last recorded holder of every mortgage of record: PLAINTIFF HEREIN (AND ANY OTHERS AS NOTED BELOW): Citifinancial, Inc. 1 Valley Street, Suite 103 Carlisle, PA 17013 UNKNOWN Name and address of every other person who has any record lien on the property: 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: UNKNOWN 7. Name and address of every other person of whom the Plaintiff has knowledge who has any interest in the property which may be affected by the sale: Tenants if any ... DOMESTIC RELATIONS Cumberland County Courthouse Hanover & Hugh Streets Carlisle, PA 17013 Karl E. Rominger, Esquire 155 South Hanover Street Carlisle, PA 17013 Robert L. O'Brien, Esquire 17 West South Street Carlisle, PA 17013 (In the preceding information, where addresses could not be reasonably ascertained, the same is indicated.) I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 PA C.S. Section 4904 relating to unsworn falsification to authorities. Le a er PA I.D. 415700 Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 DATE: September 30, 2003 r.. ' _ ? = ? ? ? r,?:. _? ,__ ? r:i r: .. ' ` 1 s. . t "7 -': ?- c[] WASHINGTON MUTUAL BANK, FA FWA PNC MORTGAGE CORP. OF AMERICA, PLAINTIFF vs. ANGIE M. WATSON AND ROBERT E. WATSON III, DEFENDANT(S) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. 02-4172 IN MORTGAGE FORECLOSURE NOTICE OF SHERIFF'S SALE OF REAL ESTATE PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129.1 TAKE NOTICE: That the Sheriffs Sale of Real Property (real estate) will be held: DATE: Wednesday, March 03, 2004 TIME: 10:00 O'clock A.M. LOCATION: Cumberland County Courthouse Carlisle, Pennsylvania 17013 THE PROPERTY TO BE SOLD is delineated in detail in a legal description mainly consisting of a statement of the measured boundaries of the property, together with a brief mention of the buildings and any other major improvements erected on the land. (SEE DESCRIPTION ATTACHED) THE LOCATION of your property to be sold is: 145 FAITH CIRCLE CARLISLE, PENNSYLVANIA 17013 THE JUDGMENT under or pursuant to which your property is being sold is docketed in the within Commonwealth and County to: No. 02-4172 JUDGMENT AMOUNT $82,686.40 THE NAMES OF THE OWNERS OR REPUTED OWNERS of this property is: ANGIE M. WATSON AND ROBERT E. WATSON III A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or governmental or corporate entities or agencies being entitled to receive part of the proceeds of the sale received and to be disbursed by the Sheriff (for example, to banks that hold mortgages and municipalities that are owed taxes) will be filed by the Sheriff of this County thirty (30) days after the sale and distribution of the proceeds of sale in accordance with this schedule will, in fact, be made unless someone objects by filing exceptions to it within ten (10) days of the date it is filed. Information about the Schedule of Distribution may be obtained from the Sheriff of the Court of Common Pleas of the within County at the Courthouse address specified herein. THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR PROPERTY. IT HAS BEEN ISSUED BECAUSE THERE IS A JUDGMENT AGAINST YOU. IT MAY CAUSE YOUR PROPERTY TO BE HELD, TO BE SOLD OR TAKEN TO PAY THEJUDGMENT You may have legal rights to prevent your property from being taken away. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights, YOU MUST ACT PROMPTLY. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET FREE LEGAL ADVICE: Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 717-249-3166 Legal Services, Inc 8 Irvine Row Carlisle, Pennsylvania 17013 717-243-9400 THE LEGAL RIGHTS YOU MAY HAVE ARE: 1. You may file a petition with the Court of Common Pleas of the within County to open the judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file an petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. 2. After the Sheriffs Sale you may file a petition with the Court of Common Pleas of the within County to set aside the sale for a grossly inadequate price or for other proper cause. This petition MUST BE FILED BEFORE THE SHERIFF'S DEED IS DELIVERED. 3. A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs must be presented to the Court of Common Pleas of the within County. The petition must be served on the attorney for the creditor or on the creditor before presentation to the court and a proposed order or rule must be attached to the petition. If a specific return date is desired, such date must be obtained from the Court Administrator's Office - Civil Division, of the within County Courthouse, before a presentation of the petition to the Court. PURCELL, KRUG & HALLER Attorneys for Plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 ALL that certain tract or parcel of land, with the buildings and improvements thereon erected, SITUATE in the Township of North Middleton, County of Cumberland. Commonwealth of Pennsylvania and described in accordance with a Plan of property made by Larry V. Neidlinger; dated February 28, 1980, as follows, to wit: BEGINNING at an iron pin on the Westerly side of Faith Circle (60 feet wide), at a corner of lot No. 156; thence extending from said point of beginning and along Lot No. 156; North 89 degrees 34 minutes 18 seconds West, the distance of 357.90 feet to a point, in line of lands of Kingsbrook Section 11; thence extending along the last mentioned lands, the two (2) following courses and distances, (1) North 25 degrees 25 minutes 35 seconds West, the distance of 15.77 feet to a point, and (2) North 43 degrees 30 minutes 42 seconds East, the distance of 49.02 feet to a point, at a corner of Lot No. 108; thence extending along Lot No. 108, South 89 degrees 34 minutes 18 seconds East, the distance of 331.29 feet to an iron pin on the Westerly side of Faith Circle; thence extending along the said side of Faith Circle, South 00 degrees 25 minutes 42 seconds East, the distance of 50.00 feet to the first mentioned point and place of BEGINNING. BEING shown as Lot Nos. 109 and 156-B on the plan of Kingsbrook, as recorded in Plan Books: 27 at Page 3 and 36 at Page 19. UNDER AND SUBJECT, NEVERTHELESS, to all rights of way, easements, restrictions and/or conditions of record. HAVING THEREON ERECTED A DWELLING KNOWN AS 145 FAITH CIRCLE, CARLISLE, PENNSYLVANIA 17013 BEING THE SAME PREMISES WHICH Ernest A. Hoffstetter and Muriel Hoffstetter, by Deed dated 3/27/98 and recorded 3/30/98 in Cumberland County Deed Book 174, Page 347, granted and conveyed unto Robert E. Watson, III and Angie M. Watson. TO BE SOLD AS THE PROPERTY OF ANGIE M. WATSON AND ROBERT E. WATSON III ON JUDGMENT NO. 02-4172 ASSESSMENT NO. 29-14-08868-078 WASHINGTON MUTUAL BANK, FA FIIUA PNC MORTGAGE CORP. OF AMERICA, PLAINTIFF vs. ANGIE M. WATSON ANODFROB ANT(S) WATSON III, INTHE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. 02-4172 IN MORTGAGE FORECLOSURE SUPPLEMENTAL AFFIDAVIT PURSUANT TO RULE 3129.1 sets forth as of the date its attorneys, Purcell, Krug & Haller, ation concerning the real props The Plaintiff in the above action, by led, the following info?YnPENNSYLVANIA 17013: the praecipe for the writ of execution was fi CARLISLE , located at 145 FAITH CIRC 1 Name and address of the Owner(s) or Reputed Owner(s): ANGIE M. WATSON A/KJA ANGIE MAE WATSON 13 PARK STREET MOUNT HOLLY SPRINGS, PA 17065-1433 ROBERT E. WATSON III AJKJA ROBERT ELLSWORTH WATSON, III 5042 FRESH POND NECK ROAD RIDGE, MD 20680-3337 address of Defendant(s) in the Judgment, if different from that listed. in (1) . Name and 2 above: SAME d address of every judgment creditor whose judgment is a record lien on the 3. Namean real property to be sold: UNKNOWN e of record: 4. Name and address of last recorded holder of every mortgage PLAINTIFF HEREIN (AND ANY OTHERS AS NOTED BELOW): Citifinancial, Inc. 1 Valley Street, Suite 103 Carlisle, PA 17013 d lien on the Property: 5. Name and address of every other person who has any recor UNKNOWN 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale: UNKNOWN 7. Name and address of every other person of whom the Plaintiff has knowledge who has any interest in the property which may be affected by the sale: Tenants if any ... DOMESTIC RELATIONS Cumberland County Courthouse Hanover & Hugh Streets Carlisle, PA 17013 Karl E. Rominger, Esquire 155 South Hanover Street Carlisle, PA 17013 Robert L. O'Brien, Esquire 17 West South Street Carlisle, PA 17013 NORTH MIDDLETON AUTHORITY 240 CLEARWATER DRIVE CARLISLE, 17013 HUBERT X GILROY, ESQUIRE 4 NORTH HANOVER STREET CARLISLE, PA 17013 (In the preceding information, where addresses could not be reasonably ascertained, the same is indicated.) I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 PA C.S. Section 4904 relating to unworn falsification to authorities. Leon P. Haller PA I.D. 915700 Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 DATE: February 4, 2004 C7 ° O .r -TI COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND I SS: I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff's Deed in which Washington Mutual Bank is the grantee the same having been sold to said grantee on the 3rd day of March A.D., 2004, under and by virtue of a writ Execution issued on the 2nd day of Oct, A.D., 2003, out of the Court of Common Pleas of said County as of Civil Term, 2002 Number 4172, at the suit of Washington Mutual Bank F A against Angie M Watson & Robert E III is duly recorded in Sheriff's Deed Book No. 262, Page 4186. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this S- day of A.D2004 Recorder of Deeds Washington Mutual Bank, FA f/k/a PNC Mortgage Corp of America VS Angie M. Watson and Robert E. Watson III In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2002-4172 Civil Tenn Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on December 04, 2003 at 6:33 o'clock PM, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendants, to wit: Angi M. Watson, by making known unto Jim Sheaffer, boyfriend of defendant, at 13 Park Street, Mt. Holly Springs, Cumberland County, Pennsylvania, its contents and at the same time handing to him personally the said true and correct copy of the same. Bryan Ward, Deputy Sheriff, who being duly sworn according to law, states that on January 12, 2004 at 8:39 o'clock P.M., he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Angie M. Watson and Robert E. Watson, III located at 145 Faith Circle, Carlisle, Pennsylvania, according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law, states he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to the within named defendant, to wit: Angie M. Watson, by regular mail to her last known address of 13 Park Street, Mt. Holly Springs, PA 17065. This letter was mailed under the date of January 12, 2004 and never returned to the Sheriffs Office. R. Thomas Kline, Sheriff, who being duly swam according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Courthouse, Carlisle, Cumberland County, Pennsylvania on March 3, 2004 at 10:00 o'clock A.M. He sold the same for the sum of $1.00 to Attorney Leon P. Haller for Washington Mutual Bank, FA f/k/a PNC Mortgage Corp. of America. It being the highest bid and best price received for the same, Washington Mutual Bank, FA f/k/a PNC Mortgage Corp. of America of P.O. Box 1169, Milwaukee, WI 53201, being the buyers in this execution, paid to Sheriff R. Thomas Kline the sum of $949.63, it being costs. Sheriffs Costs Docketing $30.00 Poundage 18.62 Posting Bills 15.00 Advertising 15.00 Acknowledging Deed 30.00 Auctioneer 10.00 Law Library .50 Prothonotary 1.00 Mileage 8.28 Levy 15.00 Surcharge 30.00 Law Journal 353.75 Patriot News 328.66 Share of Bills 29.32 Distribution of Proceeds 25.00 Sheriffs Deed 39.50 S 949.63 Sworn and subscribed to before me So Answer • y%r This day of + R. Thomas Kline, Sheriff 2004, A.D. 1--, o .nottaary?1 t ceQu. BY Q?'4 vt 4 P iteat nstateQaeputy 3b ? 1• Ge.vti? X 3 pc, 161113 y Real Estate Sale # 22 On November 13, 2003 the sheriff levied upon the defendant's interest in the real property situated in North Middleton Township, Cumberland County, PA Known and numbered as 145 Faith Circle, Carlisle, more fully described on Exhibit "A" 0 Cim filed with this writ and by this reference incorporated herein. Cim Date: November 13, 2003 By jo Real Est e Deputy EZ 9 190 AlHil, ; JO J??-Iljjo THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin) ss Michael Morrow, being duly sworn according to law, deposes and says: That he is the Controller of The Patriot News Co., a corporation organized' and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared on the 20th and 27th day(s) of January and the 3rd day(s) of February 2004. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION Ito/ ............ w..... ................... COPY Sworn to and subs this 23rd y of Febr;4 ry 2004 A.D. S A L E #22 Notarial Seal , REAL ESTATE SALE No. 22 Terry L. Russell, Notary P WE No. E SAL 172 City of Harrisburg, Dauphin Coun Civil Term my commission Expires June 6,2 006 N TARY PUBLIC Washington Mutual Bank, FA Member, Pennsybania Assocotion Of NWaties?y commission expires June 6, 2006 f/k/a PNC Mortgage Corp. of America vs CUMBERLAND COUNTY SHERIFFS OFFICE Angle M. Watson and Robert E. Watson III CUMBERLAND COUNTY COURTHOUSE Atty: Leon Haller CARLISLE, PA. 17013 DESCRIPTION ALL THAT CERTAIN tract or parcel of land, Statement of Advertising Costs with the buildings t improvements thereon To THE PATRIOT-NEWS CO., Dr. erected, situate in the Township of North Middleton, County of Cumberland, For publishing the notice or publication attached Commonwealth of Pennsylvania and described in accordance with a Plan of Property made by hereto on the above stated dates Lawry V Neidlinger, dated February 28, 1980, as Total $ 328.66 follows, to wit: BEGINNING at an iron pin on the Westerly side of Faith Circle (60 feet wide), at a comer of Lot No, 156: thence extending from said point of Publisher's Receipt for Advertising Cost The Patriot News Co., publisher of The Patriot-News and The Sunday Patriot-News, newspapers of general circulation, hereby acknowledge receipt of the aforesaid notice and publication costs and certifies that the same have been duly paid. By .................................................................... beginning and aiong Lot No. 156; North 69 degrees 34 minutes 18 seconds West, the distance of 357.90 feet to a point, in line of lands of Kingsbrook Section 11; thence extending along the last mentioned lands, the two (2) following courses and distances, (1) North 25 degrees 25 minutes 35 seconds West, the distance of 15.77 feet to a point, and (2) North 43 degrees 30 minutes 42 seconds East, the distance of 49.02 feet to a point, at a corner of Lot No. 108; thence extending along Lot No. 108, South 89 degrees 34 minutes 18 seconds East, the distance of 331.29 feet to an iron pin on the Westerly side of. Faith Circle; thence extending along the said side of Faith Circle, South 00 degrees 25 minutes 42 seconds East, the distance of 50.00 feet to the first mentioned point and place of BEGINNING. BEING shown as Lot Nos. 109 and 156-B on the plan of Kings brook, as recorded in Plan Books: 27 at Page 3 and 36 at Page 19. TINDER AND SUBJECT, nevertheless, to all rights of way, easements, restrictions and/or conditions of record. HAYING THEREON", erected a dwelling known as 145 Faith Circle, Carlisle, Pennsylvania 17013. BEING THE SAME premises which Ernest A. Hoffstetter and Muriel Hoffstetter, by Deed dated 3(27798 and recorded 3130198 in Cumberland County Deed Book 174, Page 347. granted and conveyed unto Robert E. Watson, III and Angie M. Watson. TO BE SOLD as the property of Angie M. Watson and Robert E. Watson III on Judgment No. 02-4172. ASSESSMENT NO.: 29-14-08868-078. PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 STATE OF PENNSYLVANIA : COUNTY OF CUMBERLAND : ss. Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: JANUARY 16, 23, 30, 2004 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. REAL ESTATE BALE NO. 22 Writ No. 2002-4172 Civil Washington Mutual Bank, FA, f/k/a PNC Mortgage Corp. of America vs. Angie M. Watson and Robert E. Watson, III Atty.: Leon Haller ALL that certain tract or parcel of land, with the buildings and im- provements thereon erected, SITU- ATE in the Township of North Middleton, County of Cumberland, Commonwealth of Pennsylvania and described in accordance with a Plan of Property made by Larry V. Neid- linger, dated February 28, 1980, as follows, to wit: BEGINNING at an iron pin on the Westerly side of Faith Circle (60 feet wide), at a corner of Lot No. 156; thence extending from said point of beginning and along Lot No. 156; North 89 degrees 34 minutes 18 L' a Marie Coyne, E itor SWORN TO AND SUBSCRIBED before me this 30 day of JANUARY 2004 il'WAKAL SEAL V LOIS E. SNYDER, Notary Public Carlisle Boro, Cumberland County My Commission Expires March 5, 2005 seconds West, the distance of 357- .90 feet to a point, in line of lands of Kingsbrook Section II; thence extending along the last mentioned lands, the two (2) following courses and distances, (1) North 25 degrees 25 minutes 35 seconds West, the distance of 15.77 feet to a point, and (2) North 43 degrees 30 min- utes 42 seconds East, the distance of 49.02 feet to a point, at a corner of Lot No. 108; thence extending along Lot No. 108, South 89 degrees 34 minutes 18 seconds East, the distance of 331.29 feet to an iron pin on the Westerly side of Faith Circle; thence extending along the said side of Faith Circle, South 00 degrees 25 minutes 42 seconds East, the distance of 50.00 feet to the first mentioned point and place of BEGINNING. BEING shown as Lot Nos. 109 and 156-B on the plan of Kings- brook, as recorded in Plan Books: 27 at Page 3 and 36 at Page 19. UNDER AND SUBJECT, NEVER- THELESS, to all rights of way, ease- ments, restrictions and/or condi- tions of record. HAVING THEREON ERECTED A DWELLING KNOWN AS 145 FAITH CIRCLE, CARLISLE, PENNSYLVA- NIA 17013. BEING THE SAME PREMISES WHICH Ernest A. Hoffstetter and Muriel Hoffstetter, by Deed dated 3/27/98 and recorded 3/30/98 in Cumberland County Deed Book 174, Page 347, granted and con- veyed unto Robert E. Watson, III and Angie M. Watson. TO BE SOLD AS THE PROPER- TY OF ANGIE M. WATSON AND ROB- ERT E. WATSON, III ON JUDGMENT NO. 02-4172. ASSESSMENT NO. 29-14-08868- 078. WASHINGTON MUTUAL BANK, FA FWA PNC MORTGAGE CORP. OF AMERICA, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW vs. NO. 02-4172 ANGIE M. WATSON AND ROBERT E. WATSON III, DEFENDANT(S) IN MORTGAGE FORECLOSURE RETURN OF SERVICE I h?y?eby c rtif that I have deposited in the U.S. Mails at Harrisburg, Pennsylvania on Q ?* O ; a true and correct copy of the Notice of Sale of Real Estate pursuant to PA VC.P. 3119. 1t the efendants herein and all lienholders of record by regular first class mail (Certificate of Mailing form in compliance with U.S. Postal Form 3817 is attached hereto as evidence), and also to the Defendants by Certified Mail, which mailing receipts are attached. Service addresses are as follows: ANGIE M. WATSON A/K/A Angie M. Watson A/K/A ANGIE MAE WATSON Angie Mae Watson 13 PARK STREET 145 Faith Circle MOUNT HOLLY SPRINGS, PA 17065-1433 Carlisle, PA 17013 ROBERT E. WATSON III A/K/A ROBERT ELLSWORTH WATSON, III North Middleton Authority 5042 FRESH POND NECK ROAD 240 Clearwater Drive RIDGE, MD 20680-3337 Carlisle, PA 17013 Citifinancial, Inc. 1 Valley Street, Suite 103 Carlisle, PA 17013 Hubert X. Gilroy, Esquire 4 North Hanover Street Carlisle, PA 17013 Karl E. Rominger, Esquire 155 South Hanover Street Carlisle, PA 17013 Robert L. O'Brien, Esquire 17 West South Street Carlisle, PA 17013 DOMESTIC RELATIONS Cumberland County Courthouse Hanover & Hugh Streets Carlisle, PA 17013 By _ PURCELL, & HALLER Attorneys Plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 LAW OFFICES HOWARD B. KRUG LEON P. HALLER JOHN W. PURCELL JR. JILL M. WINKA BRIAN J. TYLER NICHOLE M. STALEY O'GORMAN A (1 1719 NORTH FRONT STREET HARRISBURG, PENNSYLVANIA 17102-2392 TELEPHONE (717) 234-4178 FAX (717) 234-1206 ANGIE M. WATSON A/K/A ANGIE MAE WATSON 13 PARK STREET MOUNT HOLLY SPRINGS, PA 17065-1433 ROBERT E. WATSON III A/K/A ROBERT ELLSWORTH WATSON, III 5042 FRESH POND NECK ROAD RIDGE, MD 20680-3337 Citifinancial, Inc. 1 Valley Street, Suite 103 Carlisle, PA 17013 Karl E. Rominger, Esquire 155 South Hanover Street Carlisle, PA 17013 Robert L. O'Brien, Esquire 17 West South Street Carlisle, PA 17013 DOMESTIC RELATIONS Cumberland County Courthouse Hanover & Hugh Streets Carlisle, PA 17013 Angie M. Watson A/K/A Angie Mae Watson 145 Faith Circle Carlisle, PA 17013 North Middleton Authority 240 Clearwater Drive Carlisle, PA 17013 Hubert X. Gilroy, Esquire 4 North Hanover Street Carlisle, PA 17013 HERSHEY (717)533-3836 JOSEPH NISSLEY (1910-1982) JOHN W, PURCELL VALERIE A, GUNNOF COUNSEL NOTICE IS HEREBY GIVEN to the Defendants in the within action and those parties who hold one or more mortgages, judgments or tax liens against the real estate which is the subject of the Notice of Sale pursuant to Pennsylvania Rule of Civil Procedure 3129.1 attached hereto. YOU ARE HEREBY NOTIFIED that by virtue of a Writ of Execution issued out of the Court of Common Pleas of the within county on the judgment of the Plaintiff named herein the said real estate will be exposed to public sale as set forth on the attached Notice of Sale. YOU ARE FURTHER NOTIFIED that the lien you hold against the said real estate will be divested by the sale and that you have an opportunity to protect your interest, if any, by being notified of said Sheriffs Sale. By: Leon P. Haller PA I.D. 700 Attorney for Plaintiff WASHINGTON MUTUAL BANK, FA F/K/A PNC MORTGAGE CORP. OF AMERICA, PLAINTIFF vs. ANGIE M. WATSON AND ROBERT E. WATSON III, DEFENDANT(S) IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW NO. 02-4172 IN MORTGAGE FORECLOSURE NOTICE OF SHERIFF'S SALE OF REAL ESTATE PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129.1 TAKE NOTICE: That the Sheriffs Sale of Real Property (real estate) will be held: DATE: Wednesday, March 03, 2004 TIME: 10:00 O'clock A.M. LOCATION: Cumberland County Courthouse Carlisle, Pennsylvania 17013 THE PROPERTY TO BE SOLD is delineated in detail in a legal description mainly consisting of a statement of the measured boundaries of the property, together with a brief mention of the buildings and any other major improvements erected on the land. (SEE DESCRIPTION ATTACHED) THE LOCATION of your property to be sold is: 145 FAITH CIRCLE CARLISLE, PENNSYLVANIA 17013 THE JUDGMENT under or pursuant to which your property is being sold is docketed in the within Commonwealth and County to: No. 02-4172 JUDGMENT AMOUNT $82,686.40 THE NAMES OF THE OWNERS OR REPUTED OWNERS of this property is: ANGIE M. WATSON AND ROBERT E. WATSON III A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or governmental or corporate entities or agencies being entitled to receive part of the proceeds of the sale received and to be disbursed by the Sheriff (for example, to banks that hold mortgages and municipalities that are owed taxes) will be filed by the Sheriff of this County thirty (30) days after the sale and distribution of the proceeds of sale in accordance with this schedule will, in fact, be made unless someone objects by filing exceptions to it within ten (10) days of the date it is filed. Information about the Schedule of Distribution may be obtained from the Sheriff of the Court of Common Pleas of the within County at the Courthouse address specified herein. THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR PROPERTY. IT HAS BEEN ISSUED BECAUSE THERE IS A JUDGMENT AGAINST YOU IT MAY CAUSE YOUR PROPERTY TO BE HELD, TO BE SOLD OR TAKEN TO PAY THEJUDGMENT You may have legal rights to prevent your property from being taken away. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights, YOU MUST ACT PROMPTLY. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET FREE LEGAL ADVICE: Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 717-249-3166 Legal Services, Inc 8 Irvine Row Carlisle, Pennsylvania 17013 717-243-9400 THE LEGAL RIGHTS YOU MAY HAVE ARE: 1. You may file a petition with the Court of Common Pleas of the within County to open the judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file an petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. 2. After the Sheriffs Sale you may file a petition with the Court of Common Pleas of the within County to set aside the sale for a grossly inadequate price or for other proper cause. This petition MUST BE FILED BEFORE THE SHERIFF'S DEED IS DELIVERED. 3. A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs must be presented to the Court of Common Pleas of the within County. The petition must be served on the attorney for the creditor or on the creditor before presentation to the court and a proposed order or rule must be attached to the petition. If a specific return date is desired, such date must be obtained from the Court Administrator's Office - Civil Division, of the within County Courthouse, before a presentation of the petition to the Court. PURCELL, KRUG & HALLER Attorneys for Plaintiff 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 ALI, that certain tract or parcel of land, with the buildings and improvements thereon erected, SITUATE in the Township of North Middleton, County of Cumberland, Commonwealth of Pennsylvania and described in accordance with a flan of Property made by Larry V. Neidlinger, dated February 28, 1980, as follows, to wit BEGINNING at an iron pin on the Westerly side of Faith Circle (60 feet wide), at a corner of Lot No. 156; thence extending from said point of beginning and along Lot No. 156; North 89 degrees 34 minutes 18 seconds West, the distance of 357.90 feet to a point, in line of lards of Kingsbrook Section 11; thence extending along the last mentioned lands, the two (2) following courses and distances, (1) North 25 degrees 25 minutes 35 seconds West, the distance of 15.77 feet to a point, and (2) North 43 degrees 30 minutes 42 seconds East, the distance of 49.02 feet to a point, at a corner of Lot No. 108; thence extending along Lot No. 108, South 89 degrees 34 minutes 18 seconds East, the distance of 331.29 feet to an iron pin on the Westerly side of Faith Circle; thence extending along the said side of Faith Circle, South 00 degrees 25 minutes 42 seconds East, the distance of 50.00 feet to the first mentioned point and place of BEGINNING. BEING shown as Lot Nos. 109 and 156-B on the plan of Kingsbrook, as recorded in Plan Books: 27 at Page 3 and 36 at Page 19. UNDER AND SUBJECT, NEVERTFIELESS, to all rights of way, easements, restrictions and/or conditions of record. HAVING THEREON ERECTED A DWELLING KNOWN AS 145 FAITH CIRCLE, CARLISLE, PENNSYLVANIA 17013 BEING THE SAME PREMISES WHICH Ernest A. Hoffstetter and Muriel Hoffstetter, by Deed dated 3/27/98 and recorded 3/30/98 in Cumberland County Deed Book 174, Page 347, granted and conveyed unto Robert E. Watson, III and Angie M. Watson. TO BE SOLD AS THE PROPERTY OF ANGIE M. WATSON AND ROBERT E. WATSON III ON JUDGMENT NO. 02-4172 ASSESSMENT NO. 29-14-08868-078 Priority+ Legal Services, Inc. PO Box 540, Reisterstown, Maryland 21136 (410) 282-7000 Fax (410) 823-3299 Affidavit - Return of Private Process In Tho Court Of Common Pleas Cumberland County, Pennsylvania Case # 02-4172 Case Washington Mutual Bank VS. Angie M. Watson, et. al. The undersigned certifies to be a competent person over 18 years old and is not a party to the aforsald action. That on 10/2612003 at 2:23:00 PM at 50421 Fresh Pond Neck Rd, Ridge, MD 20680 Robert E. Watson, III was served with: Accepted by: D. Watson, father & co-resident ? Writ of Summons ? Complaint El Injunction L1 Interrogatories 11 Subpoena El Notice to Take Deposition El Order to Appear for Oral Exam L1 Supporting Documents ? Confessed Judgement 11 Show Cause Order ? Replevin ? Writ of Garnishment on Property ? Writ of Garnishment on Wages ? Civil Non-Domestic Case Information Report ? Civil Domestic Case Information Report ? Request for Production of Documents Other: Notice of Sale Additional Information : Race: White Height 6'0" Sex Male Weight 180 Hair Brown Age: 57 Other: The undersigned further solemnly declares and affirms under the penalty of perjury that the matter and facts set forth herein are true and correct to the blest of my knowledge, information s?and belief. Date: 10/31/2003 °f?'-?n c//.l( Private Process er Sworn and Subscribed to before me this ? day of in the ye> L? sell F Stern NOTARY PUBLIC Baltimore County, Maryland My Commission Expires 02/01/07 3/3?° X s?e. p_ WASHINGTON MUTUAL BANK, FA v. ANGIE M. WATSON ROBERT E. WATSON III Cumberland County Sale 3/3/2004 U. S. POSTAL SERVICE CERTIFICATE OF MAILING (In compliance with Postal Service Form 3877) Received from Purcell, Krug & Haller Postage: 1719 North Front Street Harrisburg, PA 17102 One piece of ordinary mail addressed to: Postmark: ANGIE M. WATSON A/K/A ANGIE MAE WATSON 13 PARK STREET MOUNT HOLLY SPRINGS, PA 17065-1433 U. S. POSTAL SERVICE CERTIFICATE OF MAILING (In compliance with Postal Service Form 3877) Received from Purcell, Krug & Haller Postage: 1719 North Front Street Harrisburg, PA 17102 One piece of ordinary mail addressed to: Postmark: ROBERT E. WATSON III A/K/A ROBERT ELLSWORTH WATSON, III 5042 FRESH POND NECK ROAD RIDGE, MD 20680-3337 U. S. POSTAL SERVICE CERTIFICATE OF MAILING (In compliance with Postal Service Form 3877) Received from Purcell, Krug & Haller Postage: 1719 North Front Street Harrisburg, PA 17102 One piece of ordinary mail addressed to: Postmark: DOMESTIC RELATIONS Cumberland County Courthouse Hanover & Hugh Streets Carlisle, PA 17013 ?yyS V?jsr? °j cF ev't, a 1.1-M I $ 00.900 * M19?it'cO FF1 M PC,IIE-? -? WASHINGTON MUTUAL BANK, FA v. ANGIE M. WATSON ROBERT E. WATSON III Cumberland County Sale 3/3/2004 U. S. POSTAL SERVICE CERTIFICATE OF MAILING On compliance with Postal Service Form 3877) Received from: Purcell, Krug & Haller Postage: 1719 North Front Street Harrisburg, PA 17102 One piece of ordinary mail addressed to: Postmark: Citifinancial, Inc. I Valley Street, Suite 103 Carlisle, PA 17013 U. S. POSTAL SERVICE CERTIFICATE OF MAILING (In compliance with Postal Service Form 3877) Received from: Purcell, Krug & Haller Postage: 1719 North Front Street Harrisburg, PA 17102 One piece of ordinary mail addressed to: Postmark: Karl E. Rominger, Esquire 155 South Hanover Street Carlisle, PA 17013 U. S. POSTAL SERVICE CERTIFICATE OF MAILING I'D compliance with Postal Service Form 38771 Received from: Purcell, Krug & Haller Postage: 1719 North Front Street Harrisburg, PA 17102 One piece of ordinary mail addressed to: Postmark: Robert L. O'Brien, Esquire 17 West South Street Carlisle, PA 17013 9 ll r / t USES P0,s" F Z :1tilq r ri, a f $ 00.90° NlI+ILED rR N9 -1P irr Re: WAMU V.WATSON- CM 95524 CUMBERLAND COUNTY - SALE - 03/03/04 U. S. POSTAL SERVICE CERTIFICATE OF MAILING (In compliance with Postal Service Form 38771 Received from: Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 Postage: One piece of ordinary mail addressed to: Postmark: NORTH MIDDLETON AUTHORITY 240 CLEARWATER DRIVE CARLISLE, PA 17013 U. S. POSTAL SERVICE CERTIFICATE OF MAILING (In compliance with Postal Service Form 3877) Received from: Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 Postage: One piece of ordinary mail addressed to: Postmark: HUBERT X. GILROY, ESQUIRE 4 NORTH HANOVER STREET CARLISLE, PA 17013 >qe/ ? tptrS ac,,ST ? N z -_ $ 01.801) tAAILED Fir, r3 !} <7Dr 7.51 1'! r y i cu = r:, r ^.? -corn O '<